Modern slavery remains a serious global issue, and UK businesses are expected to help tackle it. Since 2015, larger companies trading in the UK must publish an annual modern slavery statement. In 2024–25, the scrutiny has sharpened even more. The government has upgraded its statement registry and refreshed guidance to qualifying businesses. Parliament has pressed for tougher enforcement, and major buyers are pushing requirements down their supply chains to businesses of all sizes.
This guide is for business owners, directors, general counsel, and HR leaders who want clarity on whether the Modern Slavery Act applies to their business. We break down the key tests, explain what’s required if you fall under the rules, and show how taking action can protect your reputation and strengthen your supply chain practices.
If you’re unsure whether the Act applies to you or want expert help drafting or reviewing your modern slavery statement, our employment law solicitors are ready to assist.
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What is the Modern Slavery Act, and who does it apply to?
The Modern Slavery Act 2015 requires certain commercial organisations that carry on business in the UK and have a global turnover of £36m or more to publish a modern slavery statement for each financial year. The duty is on each in-scope organisation, even within a group, although many groups opt to publish a single statement that clearly identifies the entities covered.
If you’re approaching the threshold or bidding for larger customers, it pays to align with the regime early so you’re not shut out of tenders at short notice.
What are the current legal requirements?
If you are in scope, you must:
- obtain board approval
- have the statement signed by a director
- publish it on your website with a clear link from the homepage.
The Home Office guidance sets out the core areas your statement should address - policies, due diligence, risk assessment, training and effectiveness and encourages reporting on progress rather than aspirations alone. You can (and should) also upload your statement to the government registry, which increases visibility to clients, investors and NGOs.
What’s changing now and in the future?
Two themes matter for businesses:
- Rising expectations and transparency. The government has improved the central statement registry and issued updated guidance in spring 2025 to drive better quality and easier public scrutiny. Uploading is currently encouraged; ministers have signalled an intention to strengthen the regime further
- Pressure for tougher enforcement. In October 2024, the House of Lords Select Committee urged the government to close loopholes and consider mandatory supply-chain due diligence and import-ban-style measures; legal commentators expect movement under the current Parliament.
Public procurement is also tightening through the Procurement Act 2023, and Cabinet Office policy notes that modern slavery offences can already trigger exclusion from public tenders. Private buyers are also following suit in their supplier codes and contracts.
Do businesses below £36m need to act?
Strictly, you’re not legally required to publish a statement if you fall below the threshold. However, many organisations now choose to publish voluntarily. Larger customers often demand it during a tender process, investors expect it as part of ESG credentials, and the public registry makes due diligence quick for potential buyers.
Several parliamentary and media reports have warned that UK enforcement must catch up, so taking a proactive stance is increasingly a commercial necessity. If you’re scaling, aligning early also avoids a scramble when you cross £36m.
What are the risks of non-compliance?
For in-scope businesses, failing to publish a meaningful statement risks public criticism, lost bids and potential future penalties if the government adopts the Lords’ recommendations. Even for those below the threshold, not engaging with supply-chain risk can lead to exclusion from panels and reputational damage once buyers check the registry and your website. Public bodies already have tools to debar lawbreakers under procurement rules.
How should a company prepare or refresh its modern slavery statement?
Think of the statement as the visible tip of a practical programme:
- Governance and accountability. Nominate an executive owner, keep the board involved, and record approvals each year.
- Risk-based due diligence. Map your supply chain and prioritise by risk- sector, geography and labour profile - using questionnaires, audits or third-party certifications where proportionate. Update supplier contracts so obligations flow down through the chain (for example, through back-to-back clauses and SLAs).
- Training and escalation. Train procurement and operational teams to spot red flags and know how to escalate concerns; record participation and outcomes.
- Show progress, not perfection. The latest guidance encourages reporting outcomes and next steps, not just policies. Set metrics you can genuinely track year-on-year.
For practical contract levers and supply-chain risk tips, see our articles on ESG clauses and managing supply-chain risk.
When should you seek legal advice?
It is advisable to get support if you’re drafting your first statement, responding to a major customer’s due diligence questionnaire, refreshing supplier terms, or preparing to upload to the registry. It’s also wise to align modern slavery work with your broader ESG strategy and upcoming procurement rules so initiatives aren’t duplicated.
Our experienced employment law solicitors help organisations design proportionate, commercial programmes: statements that stand up to scrutiny, supplier contracts that actually bite, and training that equips your people to act.
Conclusion
Modern slavery compliance is no longer a box-ticking exercise for the largest companies only. With official guidance strengthened, the public registry maturing and buyer due diligence intensifying, businesses of all sizes should decide where they stand, and show their work. Start with governance, risk-based due diligence and clear reporting, then improve year by year.
If you’d like pragmatic help to prepare or upgrade your modern slavery statement—and embed the right controls across your supply chain, speak to our employment law solicitors today. We’ll make it clear, practical and proportionate.
