New statutory guidance on the Modern Slavery Act 2015 for supply chains
min read
Key takeaways
- The 2025 statutory guidance clarifies what good and best practice looks like under the Modern Slavery Act 2015.
- Businesses are expected to identify and disclose real modern slavery risks and incidents, not report zero risk.
- Continuous improvement and collaboration are key.
- Alignment with the guidance will help futureproof businesses.
Overview of the Modern Slavery Act 2015
The UK Modern Slavery Act 2015 has now been in force for a decade. Section 54 of the Act requires organisations carrying on business in the UK, with a consolidated global turnover of £36 million, to publish an annual modern slavery statement.
This statement must set out the steps the organisation has taken to ensure that slavery and human trafficking are not taking place in its own business or supply chains. Alternatively, it must state that it has taken no such steps. The statement must be approved by the board, signed by a director, and published prominently on the organisation’s website.
Purpose of the 2025 statutory guidance
In March 2025, the UK Government published new statutory guidance on how businesses should comply with section 54 of the Act. While the law itself has not changed, the guidance provides much needed clarity on the Government’s expectations around both the content and quality of modern slavery statements.
The guidance is designed to raise standards and to promote more meaningful, consistent and transparent reporting. Although primarily aimed at organisations within scope of the Act, it also strongly encourages smaller businesses to publish voluntary modern slavery statements.
Required reporting areas under section 54
The guidance expands on the six reporting areas set out in section 54 and explains what effective disclosure looks like in each case. These areas cover an organisation’s structure, business model and supply chains, as well as its modern slavery policies and due diligence processes.
Businesses are also expected to explain how they assess and manage modern slavery risks, how they measure the effectiveness of their actions, and what training is provided to relevant staff. The emphasis is on clear, specific and outcome focused reporting rather than generic statements.
Alignment with international best practice frameworks
A key message from the guidance is that it does not reinvent the wheel. It aligns closely with established international frameworks for human rights due diligence, including the UN Guiding Principles on Business and Human Rights (UNGPs).
Businesses are strongly encouraged to adopt these frameworks and to take a holistic approach to human rights risks across their operations and supply chains. This approach extends beyond modern slavery alone and reflects a broader expectation of responsible business conduct.
Expectation to identify and disclose real risks
The guidance makes it clear that meaningful due diligence will uncover risks and actual instances of modern slavery. Statements that report no risks or incidents are expressly described as inadequate.
Transparency is therefore critical. Businesses are expected to be open about where risks exist, what has been identified, and how those risks are being addressed. This represents a significant shift away from purely defensive reporting.
Focus on continuous improvement over zero risk
The objective of the guidance is not the elimination of all risk, which is recognised as unrealistic. Instead, the focus is on continuous improvement over time.
The guidance distinguishes between level 1 good practice and level 2 best practice disclosures. As organisations become more familiar with their obligations, they are expected to progress year on year, strengthen their due diligence and outcomes and graduate from level 1 to including more level 2 disclosures.
Importance of collaboration across supply chains
Collaboration is a central theme of the guidance. Businesses are expected to engage with a wide range of stakeholders, including internal teams, suppliers, non governmental organisations and trade unions.
For organisations at the top of supply chains, there is a clear expectation that they should minimise unnecessary burdens on smaller suppliers. This includes streamlining data requests and taking a fair share of the costs associated with due diligence activities.
Limits of audits as a due diligence tool
The guidance cautions against over reliance on audits. While audits can play a role in identifying risks, they are recognised as an imperfect and sometimes unreliable tool.
Businesses are expected to supplement audits with other forms of engagement, particularly direct engagement with workers and workers’ representatives. This reflects a broader understanding of how modern slavery risks manifest in practice.
Enforcement risks and future reform
Although the guidance does not change the law, it reinforces existing enforcement mechanisms. Organisations that fail to produce a modern slavery statement may face a High Court injunction, with the risk of unlimited fines for non compliance.
Looking ahead, the Government has signalled its intention to reform the Modern Slavery Act to strengthen due diligence and disclosure requirements in line with international best practice. Investors, lenders and corporate customers are already assessing alignment with the guidance, and some large organisations are beginning to expect best practice disclosures as a condition of doing business.
For brands that publicly promote their social impact credentials, failure to align with the guidance also increases exposure to allegations of social washing.
Further guidance and next steps
Aligning policies, processes and disclosures with the 2025 statutory guidance is both a risk mitigation exercise and a strategic opportunity. Taking action now will help businesses strengthen their approach to human rights risks and prepare for future regulatory change.
For a more detailed explanation of the issues covered in this article, please watch the accompanying video. For tailored advice on alignment with the guidance or related ESG matters, please contact Kerry Stares or your usual Charles Russell Speechlys contact.
