UK Immigration and Asylum Bill transforms modern slavery reporting by businesses

Section 54 of the Modern Slavery Act 2015 currently requires commercial organisations with annual turnover exceeding £36 million to publish an annual slavery and human trafficking statement. Since it came into force, compliance has been inconsistent. 

The existing framework sets out topics a statement may cover. These include an organisation's structure, its policies, its due diligence processes and staff training. However, organisations are not legally required to address any of them specifically and there has been no direct financial penalty for non-compliance. The result has been significant variation in the quality and substance of statements across sectors. The Immigration and Asylum Bill now represents the most significant reform to this regime, making it tougher and more prescriptive.

Mandatory prescribed content

For the first time, statements must address specified topics as set out in the bill, including information about the organisation's structure, its operations and its supply chains. Where an organisation has not taken particular steps, it must say so explicitly and give reasons why. 

A business with no modern slavery programme in place can still technically comply with the requirements, but it must explain in writing that it has no modern slavery programme, and this must be personally signed off by a director. Businesses that have historically treated the statement as a box-ticking exercise will need to reconsider their approach.

Accuracy statement and group signing

Each statement must include a declaration by the signatory (being a director or equivalent) that it is accurate to the best of their knowledge and belief, and must also receive board approval. 

Parent undertakings may sign on behalf of subsidiaries. This should simplify reporting for large groups, but it creates significant accountability for the signing director. Groups with subsidiaries operating in different sectors or jurisdictions will need governance processes that give sufficient confidence to the signatory to make that declaration.

Extension to public bodies

Reporting obligations will be extended to public authorities whose total budget meets a threshold to be set in secondary legislation. NHS trusts, local authorities, universities and central government departments with supply chains carrying material modern slavery risk fall within scope. The precise threshold is to be set by regulations, and public bodies should monitor this closely.

Electronic submission

Statements must be submitted to the secretary of state by specified electronic means within six months of the end of the relevant financial year. This mandatory electronic submission will make it easier for the government to monitor who has and has not submitted, and what their statements actually say. This visibility is set to make enforcement more likely than it has been to date.

Financial penalties

Non-compliance without reasonable excuse will attract a financial penalty of up to the greater of 1% of total annual turnover (for commercial organisations) or total budget (for public authorities), or £1 million. For large organisations, 1% of turnover will far exceed £1 million.

This transforms section 54 from a largely unenforced obligation into one with significant commercial consequences. The detailed enforcement framework, including investigation procedures, warning notices and appeal rights, will be set out in secondary legislation.

No mandatory due diligence

The bill does not introduce mandatory human rights due diligence (HRDD). The Independent Anti-Slavery Commissioner has already criticised this omission, warning that the UK "has fallen behind our international partners and is becoming a dumping ground for forced labour goods".

The EU's Corporate Sustainability Due Diligence Directive takes a wider approach, requiring in-scope companies to identify, prevent and remediate human rights and environmental harms across their supply chains. Following the Omnibus I package earlier this year, its scope has been narrowed, with the employee threshold rising from 1,000 to 5,000 and the turnover threshold from €450m to €1.5bn. The requirements under the directive come into force from July 2029. As well as this, the EU Forced Labour Regulation comes into full effect from December 2027, blocking goods with forced labour in their supply chain from EU markets.

Chris Bryant, then minister for trade policy under Keir Starmer's government, had stated publicly that he expected the government to introduce mandatory HRDD before the end of this parliament. In June, a private members' bill was introduced into the House of Lords which would impose a duty to prevent human rights and environmental harms as well as introducing criminal liability and penalties up to 10% of global turnover. The prospects of this bill progressing through the House of Commons under the new government led by Andy Burnham are currently unknown.

What happens next

The Immigration and Asylum Bill passed its second reading on 13 July 2026 by 264 votes to 90. The Public Bill Committee meets for the first time on 10 September, is accepting written evidence at scrutiny@parliament.uk, and is expected to report by 3 November.

Osborne Clarke comment

The bill is a step in the right direction for the prevention of modern slavery in the UK but still falls short of the requirements being introduced in the EU. 

Businesses should review their modern slavery statement processes in light of the additional requirements proposed under the bill, and monitor the progress of both this bill and the private members' bill in the House of Lords for any further changes to reporting or due diligence obligations.