The tracker · United Kingdom
The UK Modern Slavery Act requires annual statements but sets no content standards or penalties, so buyers often wrongly cite it for heavy supplier data requests. A June 2026 bill would make statements prescriptive and introduce financial penalties.
Public Bill Committee began scrutiny of the section 54 amendments on 10 September 2026 and is expected to report by 3 November.
In plain language
Under Section 54 of the UK Modern Slavery Act, large companies must publish an annual statement detailing their efforts to identify, prevent, and mitigate modern slavery in their supply chains. However, this mandate acts more as a transparency exercise than a strict regulatory standard. The law allows immense flexibility, meaning a company can legally comply even if its statement explicitly admits that no action was taken. Furthermore, there is no regulatory body assigned to audit these reports, nor are there financial penalties for publishing vague or weak disclosures. If a company fails to publish a statement altogether, a court's only recourse is to issue an injunction forcing them to produce one; it cannot punish the business for the actual content of the report.
Because the statutory threshold is so low, a significant disconnect has emerged between what the law requires and what the market demands. Corporate buyers frequently ask their suppliers for extensive compliance documentation, often incorrectly claiming that UK law forces them to do so. In reality, the legislation establishes almost no baseline for mandatory due diligence. When buyers impose these heavy reporting requirements, they are typically driven by internal corporate risk policies or the pressure to comply with stricter international frameworks, such as the EU's regulations, rather than genuine UK legal obligations.
This purely disclosure-based environment may soon change. On 30 June 2026 the government tabled amendments to section 54 in the Immigration and Asylum Bill, which reached its second reading on 13 July 2026. Statements would have to cover set topics, including risk assessment, policies, due diligence, training and effectiveness, and would need board approval. Public authorities would be brought into scope. The Secretary of State could impose penalties of up to the greater of 1 million pounds or 1 percent of total turnover. The Public Bill Committee began its detailed scrutiny on 10 September 2026 and is expected to report by 3 November. The bill has not yet passed, and it strengthens reporting rather than creating a full due diligence duty, but it moves the UK closer to the European model.
Obligations
Covered organisations must publish a board-approved, director-signed statement on their website with a prominent link.
The statutory guidance recommends covering structure, policies, due diligence, risk assessment, effectiveness and training, though content remains formally optional.
Timeline
Act received Royal Assent.
Independent review recommended substantial strengthening of section 54.
House of Lords committee found the act no longer world-leading and urged due diligence legislation.
Government response and consultation kept reform options open without a bill.
Government introduced amendments to section 54 within the Immigration and Asylum Bill, strengthening reporting requirements ahead of a promised standalone due diligence law.
Immigration and Asylum Bill, carrying the section 54 amendments, reached its second reading.
Public Bill Committee began detailed scrutiny of the bill, with a report expected by 3 November 2026.
Changelog
Added the Commons committee stage, which began on 10 September 2026 with a report expected by 3 November.
Added the bill's second reading and proposed penalty regime; moved the act to the in force group, since section 54 applies today; removed dashes from the summary.
Reform debate status refreshed following ministerial statements.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology