UK Modern Slavery Act reporting set to become more demanding: What the proposed reporting changes mean for businesses 

UK Modern Slavery Act reporting set to become more demanding: What the proposed reporting changes mean for businesses 

GoodBlog | read time: 6 min

Published: 3 September 2026

Proposed changes to Section 54 of the Modern Slavery Act in the Immigration and Asylum Bill would alter the UK’s modern slavery reporting requirements, making the contents of modern slavery statements more prescriptive and introducing reporting on effectiveness. As the Bill progresses through the UK Parliament, companies can use the time to evaluate their current modern slavery approach against the new reporting expectations. 

What is changing to Section 54? 

The Immigration and Asylum Bill, introduced on 30 June 2026, proposes key changes to the UK’s modern slavery reporting requirements. The reforms address some of the criticism of Section 54 relating to the lack of specific reporting requirements on steps taken to identify, prevent and address modern slavery in the supply chain. 

Under the current Section 54 regime, companies must publish a modern slavery statement each year if they do business in the UK and have an annual turnover of £36 million or more. The content of the statement remains flexible, and while government guidance sets out recommended areas for reporting, these are advisory rather than mandatory, and a statement saying no measures have been taken is permissible.  

The Immigration and Asylum Bill would change this by making specific parts of the modern slavery statement mandatory. Organisations would be required to report on risk assessment procedures, policies, due diligence and training. They would also be required to report on the effectiveness of their approach to addressing modern slavery and human trafficking.  

Importantly, the Bill would strengthen board-level accountability for modern slavery statements. Companies are already required to have statements approved by the board and signed by a director, or equivalent, but the Bill would introduce an additional obligation for the signatory to declare that the statement is accurate to the best of their knowledge and belief. It also proposes a hard deadline for publication, no later than six months after the end of the financial year, and introduces significant financial penalties for non-compliance of up to the greater of 1% of turnover or £1 million. 

The proposed regime would extend reporting requirements to qualifying public authorities, with the relevant budget thresholds still to be set. While central government and NHS bodies already have mandatory requirements to identify and manage modern slavery risks in procurement, the new duty would increase transparency and accountability for how all qualifying authorities manage those risks. For suppliers, this could mean increased scrutiny of controls by public bodies looking to evidence how they are identifying and managing modern slavery risks in their supply chains. 

Although reporting areas would be mandated, increasing transparency and accountability, the Bill does not create a standalone legal duty to conduct modern slavery due diligence or demonstrate that controls are effective. In specified circumstances, organisations would be able to state that they have not undertaken particular activities or assessed effectiveness but would need to explain why.  

The Bill is still at an early stage. The Public Bill Committee is due to scrutinise it from 10 September 2026 and is expected to report by 3 November. The timetable for implementation has yet to be set, current expectations are that the new rules could apply to statements covering financial years from 2027 onwards. 

From reporting activities to reporting effectiveness 

Alongside the other specified reporting areas, the proposed framework introduces a requirement to report on programme  effectiveness. 

Currently, most companies’ modern slavery statements include only a limited set of year-on-year KPIs aimed at measuring performance, and these tend to focus narrowly on training completion. While this shows participation, it does not demonstrate whether employees in relevant roles actually understand modern slavery risks or know how to respond to concerns. Similarly, organisations routinely report the number of suppliers screened. This shows the reach of a due diligence process, but not whether it is identifying incidents of modern slavery or trafficking and driving effective action. 

The Bill does not prescribe a methodology or set of KPIs for measuring effectiveness. Organisations will therefore need to determine how best to assess whether their approach is working and what difference it is making. This means moving beyond measures of activity, such as training completion or supplier screening, towards indicators that provide evidence of how well controls are working and whether they are reducing risks or improving outcomes. 

The effectiveness review will matter most to boards in the context of the proposed accuracy declaration. While this would not constitute a formal assurance of effectiveness, senior leaders will need sufficient oversight of the organisation’s modern slavery risks, controls and performance to be comfortable approving the statement and making that declaration. This could make it harder for statements to be treated simply as a reporting exercise, particularly where they identify gaps or explain that particular measures have not been undertaken. 

What does this mean in practice? 

Organisations seeking to provide credible evidence against the new reporting requirements will need reliable information about their risks, controls and outcomes. 

This means going beyond simply mapping risks and cataloguing controls, to testing whether those controls actually work. Are third-party screening processes identifying actual and potential risks in practice? Are supplier audits identifying recurring issues and helping to reduce them over time? Are corrective action plans being developed in collaboration with third parties and is implementation followed up on? Are affected stakeholders consulted to measure the real-world impact of mitigation measures? 

Much of the relevant information may already sit within current processes, including risk assessments, supplier due diligence, audits, training, grievances and remediation mechanisms. The challenge is to bring this information together in a way that allows the organisation to understand not only what it has done, but what difference those activities have made. 

What should companies do now? 

While the legislation may evolve as it progresses through Parliament and the implementation timetable is still to be finalised, companies should nevertheless use the time available to assess how best to meet these new reporting requirements and consider the approach they wish to take. 

For those looking to follow best practice, GoodCorporation recommends the following key steps:  

Evaluate current reporting against the proposed Section 54 requirements 

Check whether your current statement addresses the proposed reporting areas and whether you have sufficient evidence to support what is being reported. Where information is missing, consider whether further work is needed or, where the Bill allows an explanation, whether there is a clear and defensible rationale that senior leaders can approve. 

Assess the effectiveness of your current approach  

• Review how modern slavery risks are currently identified: Check whether the current risk assessment provides a clear, prioritised picture of where modern slavery might arise across operations and supply chains, including higher-risk countries, sectors, workforces and business relationships. This should provide a sound basis for deciding where further action is needed. 

• Review policies and due diligence: Assess whether policies and due diligence processes are aligned with the risks identified and are operating as intended across relevant suppliers, contractors and other business partners. Consider where stronger controls or better monitoring may be needed. 

• Review training and awareness: Check whether training and communications reach the people most likely to encounter or need to respond to incidents of modern slavery and whether these measures are actually improving their understanding and ability to respond  

• Review how effectiveness is currently measured, if at all. Consider whether existing measures provide meaningful evidence that controls are working and where further testing or information may be needed. 

Establish where effectiveness needs to be assessed further and start collecting information 

Identify where further information or testing may be needed to report on effectiveness and d. Develop a proportionate set of indicators that provide meaningful evidence of whether controls are working, and whether they are reducing risks or improving outcomes for people affected. 

The effectiveness assessment will relate to the financial year being reported on. Companies should therefore avoid leaving the assessment until the statement is due as the information required will need to reflect how the organisation’s approach operated during the year. This will mean considering how best to capture and evaluate the information needed ahead of time.  

Prepare for senior-level review 

While the proposed accuracy declaration does not require formal assurance, organisations should still consider how information will be brought together and reviewed before the statement is approved, and what the signatory will need to see to make that declaration with confidence. 

This is particularly important where the statement reports on gaps in risk assessment, due diligence or other key reporting areas. Although the Bill allows organisations to explain why particular activities have not been undertaken, senior leaders will need sufficient information to understand and approve the position being reported. 

How GoodCorporation can help 

While the Bill is still progressing through Parliament, companies can use the time to assess their current approach and consider where further information or improvements may be needed to meet the proposed reporting expectations. Reviewing current risk assessment, due diligence, training and effectiveness measures now can provide a stronger basis for future statements and give senior leaders greater confidence in what they are being asked to approve. 

GoodCorporation works with companies to assess, build and embed effective modern slavery prevention programmes. We use our Human Rights and Modern Slavery Framework to help organisations strengthen their risk management and reporting in line with best practice and the Transparency in Supply Chains Statutory Guidance. We also conduct modern slavery risk assessments, develop company training programmes, support with statement drafting and help organisations identify meaningful KPIs through which they can report on the effectiveness of their programme.  

This can provide a stronger basis for future modern slavery statements and for senior management and board review. To find out more about our work on human rights and modern slavery visit our webpage or contact us to speak to a member of our team.

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