UK Bill Could Expand Modern Slavery Reporting for Public Bodies and Suppliers
The UK Government plans to advance Modern Slavery Act reporting reforms through the Immigration and Asylum Bill, potentially extending duties to public-sector organisations and introducing fines of up to £1 million or 1% of turnover or budget, whichever is higher. Public-sector contractors should review supplier-risk records and remediation evidence, while the broader due-diligence regime and forced-labour import ban remain undecided.
Key Signals
- UK bill could extend modern-slavery reporting duties to public-sector organisations
- Proposed non-compliance penalties reach £1 million or 1% of turnover or budget
- Public-sector contractors should assess supplier records and remediation evidence
- No implementation deadline is specified in the source
- Broader due diligence and forced-labour import ban remain undecided
The UK Government says it will advance changes to modern-slavery supply-chain reporting through the Immigration and Asylum Bill, following sustained calls from the Business and Trade Committee for stronger safeguards against forced labour. The Committee’s work arose in part from its examination of the UK’s trade relationship with the United States and concerns that the UK could become a destination for products restricted in other markets because of forced-labour concerns. The Government’s response, published as the Fourth Special Report of Session 2026–27, describes reforms intended to raise standards for businesses and public-sector organisations in reporting on and addressing exploitation in their supply chains.
The proposed measures would amend the existing Transparency in Supply Chains reporting requirements under the Modern Slavery Act 2015. They include requiring statements to cover specified topics, making publication on the Modern Slavery Statement Registry mandatory, clarifying publication deadlines and approval requirements, and extending reporting duties to public-sector organisations. The proposals also include powers to impose financial penalties for non-compliance. The stated maximum could reach £1 million or 1% of an organisation’s turnover or budget, whichever is higher. The precise operation of these measures depends on the legislation and any subsequent implementation arrangements.
For government contractors, an extension of reporting duties to public bodies could create practical requirements across public-sector supply chains, even where a supplier is not itself directly covered by the new rules. Buyers may seek clearer evidence about supplier identification, risk assessment, corrective action, and reporting processes. Contractors should therefore assess whether their supplier records and remediation documentation can substantiate what they report, and whether responsibility for collecting and validating information is clearly assigned across subcontractors and other suppliers. These are prudent readiness steps, not confirmed requirements or a specified implementation timetable.
The wider policy direction remains unsettled. The Government response refers to the Responsible Business Conduct Review, which examined the existing framework and considered alternative approaches to improving responsible business practices. However, the source does not establish that a broader mandatory due-diligence regime or a ban on imports made using forced labour has been confirmed. Public-sector buyers and contractors should distinguish the reporting reforms being advanced through the bill from those undecided policy options, and monitor the bill’s provisions and any later implementation guidance before treating proposed changes as final obligations.
- The Government says it will take forward modern-slavery supply-chain reporting reforms through the Immigration and Asylum Bill.
- Proposed reforms would extend reporting duties to public-sector organisations; the final scope depends on legislation and implementation arrangements.
- Modern-slavery statements could be required to address specified topics and be published on the Modern Slavery Statement Registry.
- The proposals would clarify statement publication deadlines and approval requirements.
- Proposed financial penalties could reach £1 million or 1% of turnover or budget, whichever is higher.
- Public-sector contractors should review supplier records, risk-assessment processes, and documentation showing how identified risks were addressed.
- The source specifies no implementation deadline; contractors should not assume a compliance date from this announcement.
- A broader mandatory due-diligence regime and a forced-labour import ban remain undecided, rather than confirmed requirements.
- The Business and Trade Committee has called for stronger safeguards, including due diligence and restrictions on goods produced using forced labour.
- The Government’s response also references the Responsible Business Conduct Review as part of its consideration of responsible-business approaches.
Agencies
- UK Government
- Business and Trade Committee
Vendors
- Shein
Locations
- United Kingdom
- United States
Sources
- Forced Labour in Supply Chains: Government to LegislateSolicitor News · Nov 10