The Modern Slavery Act 2015 consolidated UK slavery and human trafficking offences and introduced new measures to combat exploitation. For most businesses, the part that matters is section 54, the "transparency in supply chains" duty, which came into force in October 2015.

Section 54 requires large commercial organisations carrying on business in the UK to publish an annual slavery and human trafficking statement describing what they are doing to ensure modern slavery is not occurring in their business or supply chains. The duty is a transparency obligation: it compels disclosure rather than prescribing a specific standard of conduct, and is enforced by court injunction rather than by direct fines.

What is the section 54 transparency-in-supply-chains duty?

Section 54 of the Modern Slavery Act 2015 requires certain commercial organisations to prepare a slavery and human trafficking statement for each financial year.

The statement must set out either:

  • the steps the organisation has taken during the financial year to ensure that slavery and human trafficking are not taking place in any of its supply chains or in any part of its own business; or
  • a statement that the organisation has taken no such steps.

The duty is a transparency obligation. The law does not mandate a particular level of anti-slavery activity; it requires organisations to be open about what they are (or are not) doing.

Which organisations are caught? (the £36 million turnover threshold)

The duty applies to a commercial organisation that:

  • supplies goods or services;
  • carries on a business, or part of a business, in any part of the UK (wherever it is incorporated); and
  • has a total annual turnover of £36 million or more.

The £36 million figure is set by The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 (SI 2015/1833). Turnover is calculated as the organisation's turnover plus the turnover of any subsidiary undertakings, including subsidiaries operating wholly outside the UK. A parent meeting the threshold must report; individual subsidiaries may also need their own statements if they independently meet the criteria.

What must a slavery and human trafficking statement cover?

Section 54(5) lists six areas the statement may include. Under the Act these are suggested rather than mandatory, but Home Office statutory guidance encourages organisations to address all six:

  1. the organisation's structure, its business and its supply chains;
  2. its policies in relation to slavery and human trafficking;
  3. its due diligence processes;
  4. the parts of its business and supply chains where there is a risk of slavery and human trafficking, and the steps taken to assess and manage that risk;
  5. its effectiveness in ensuring slavery and human trafficking is not taking place, measured against appropriate performance indicators; and
  6. the training about slavery and human trafficking available to its staff.

There is no prescribed length or format, but the guidance favours clear, specific, year-on-year disclosure over boilerplate.

Who has to approve and sign the statement?

The statement carries board-level accountability. The approval requirement depends on the organisation's legal form:

  • Body corporate (other than an LLP): approved by the board of directors (or equivalent management body) and signed by a director.
  • Limited liability partnership (LLP): approved by the members and signed by a designated member.
  • Limited partnership (1907 Act): signed by a general partner.
  • Any other partnership: signed by a partner.

Home Office guidance recommends the statement clearly states that approval was given and records the date of approval. This sign-off requirement is designed to ensure senior ownership of the issue rather than treating it as a routine compliance filing.

How must the statement be published, and what is the government registry?

Publication rules under section 54:

  • If the organisation has a website, it must publish the statement there and include a link in a prominent place on the homepage.
  • If it has no website, it must provide a copy in writing within 30 days of a written request.

A statement must be produced for each financial year. Government guidance recommends publishing within six months of the financial year end.

Since 2021 the UK government has operated an online modern slavery statement registry, a central, searchable database where organisations can upload statements. Using the registry is currently voluntary but strongly encouraged; the government has stated its intention to make registry submission mandatory in future.

What happens if an organisation does not comply?

There is no direct or automatic financial penalty under section 54 for failing to publish a statement.

The sole statutory enforcement mechanism is that the Secretary of State may bring civil proceedings in the High Court for an injunction requiring the organisation to comply.

The practical consequences are therefore:

  • Court order: an organisation that ignores an injunction would be in contempt of court, which can carry an unlimited fine.
  • Reputational pressure: non-compliance is visible to investors, customers, NGOs and civil-society watchdogs, who actively track missing or weak statements.

In practice, the regime has relied heavily on transparency and reputational accountability rather than enforcement action.

What strengthening reforms have been proposed?

Section 54 has been widely criticised as having "weak teeth." Reviews — including the independent review of the Modern Slavery Act and a House of Lords committee — have proposed reforms, and the government has stated it will bring forward a strengthened modern slavery system. Frequently proposed changes include:

  • making the six reporting areas mandatory rather than optional;
  • introducing a single, fixed annual reporting deadline;
  • making submission to the government registry mandatory;
  • extending the reporting duty to certain public bodies;
  • introducing civil financial penalties for non-compliance; and
  • creating a single enforcement body for labour market and supply-chain obligations.

These remain proposals: as of mid-2026 they have not been enacted, and no firm legislative timetable has been confirmed. Organisations should monitor Home Office announcements for change.

Frequently asked questions

Who has to comply with the Modern Slavery Act's reporting duty?

Any commercial organisation that supplies goods or services, carries on a business (or part of one) in the UK, and has a total annual turnover of £36 million or more — including the turnover of its subsidiaries. The organisation can be incorporated anywhere in the world as long as it does business in the UK.

Is the £36 million threshold based on UK turnover only?

No. It is based on total global turnover, calculated as the organisation's turnover plus that of any subsidiary undertakings (including overseas subsidiaries). What must be UK-connected is the carrying on of business, not the turnover.

Are the six reporting topics mandatory?

Not under the current Act. Section 54(5) lists six areas a statement may include, and Home Office guidance encourages covering all six, but they are not legally compulsory. Making them mandatory is one of the most commonly proposed reforms.

Does the statement really need board and director sign-off?

Yes, for bodies corporate the statement must be approved by the board of directors and signed by a director. LLPs need member approval and a designated member's signature; partnerships are signed by a (general) partner. This board-level accountability is a core part of the duty.

What is the penalty for not publishing a statement?

There is no direct financial penalty. The only statutory enforcement is the Secretary of State seeking an injunction in the High Court. Ignoring such an injunction would be contempt of court, punishable by an unlimited fine. In practice, reputational consequences have been the main deterrent.

Do I have to submit my statement to the government registry?

Not yet. Publishing on the modern slavery statement registry is currently voluntary but strongly encouraged. The government has said it intends to make registry submission mandatory in future, so many organisations submit now to prepare.

Official sources