As organizations work through the complicated regulations surrounding human rights due diligence, one regulation stands out for its global influence and reach: the United Kingdom (UK) Modern Slavery Act 2015 (MSA). With businesses worldwide searching for clarity on compliance requirements, understanding this landmark legislation is the best place to begin for any organization committed to ethical supply chain management. Whether your organization is at the start of its responsible sourcing journey or already a few years in, refreshing your teams with the foundations of the MSA is a key step for the continued development for a procurement team.
What is the UK Modern Slavery Act?
The introduction of the UK MSA in 2015 was groundbreaking as it established one of the world's first transparency-in-supply-chains requirements for businesses. The MSA became law on March 26, 2015, and its influence extended beyond UK borders, which was a new scope in the world of forced labour regulation. Essentially, any commercial organization with an annual turnover of £36 million (approximately $48.5 million) or more that conducts business in any part of the UK must comply with the MSA regardless of where the organization is incorporated.
This extraterritorial reach meant that US-based companies, Asian manufacturers, and organizations across the globe fall within the scope of the MSA if they supply goods or services to the UK and meet the revenue threshold. For many international organizations, the MSA represented the first encounter with mandatory modern slavery reporting requirements, which continues through to today.
Modern slavery statement requirements
Section 54 of the MSA, known as the Transparency in Supply Chains provision, requires qualifying organizations to publish an annual modern slavery statement within six months of their financial year end. This statement must outline steps taken to prevent modern slavery in operations and supply chains or explicitly acknowledge if no steps have been taken.
The statement must be:
- Approved by the board of directors and signed by a director.
- Published prominently on the company's website with a link on the homepage.
- Updated annually to reflect current practices and progress.
While the MSA suggests that annual modern slavery statements should cover six areas, these elements are not mandatory:
- Organizational structure
- Policies
- Risk assessment
- Due diligence processes
- Training
- Effectiveness measures
While the passing and enforcement of the MSA compelled organizations to more thoroughly review forced labour risks in their supply chains, some for the first time, its discretionary and somewhat vague language has resulted in inconsistent reporting that undermines the law's transparency objectives.
Enforcement gap and calls for reform
The MSA does not currently impose direct penalties for failing to comply with transparency requirements. Instead, enforcement relies on reputational risk and the potential for government intervention.
This lack of direct penalties has drawn significant criticism. A House of Lords committee published a review in October 2024 of the MSA's effectiveness, concluded that it was no longer world leading, and as a result, recommended several reforms, including:
- Making modern slavery statement content mandatory rather than discretionary.
- Introducing proportionate civil penalties for noncompliance.
- Extending requirements to public sector bodies with equivalent budgets.
- Creating a single enforcement body to oversee compliance.
These proposed changes indicate a move toward more stringent mandatory due diligence requirements, bringing the UK in line with newer legislation in other jurisdictions.
Despite the lack of penalties, the passing of the MSA has resulted in significantly more organizations conducting forced labour due diligence across their supply chains, centering human rights risks in procurement conversations and decisions. As of publication, over 20,800 unique modern slavery statements have been submitted as part of compliance with the MSA.
Why this matters now
Global expectations for human rights due diligence in supply chains are heading into a new direction.
Global regulations are catching up: Laws in the European Union (EU), Germany, Norway, Australia, and Canada are introducing mandatory human rights due diligence with penalties, audits, and legal liability.
Investors pressure on transparency: Environmental, social, and governance (ESG) expectations now require real action and intentional due diligence, not symbolic policies or statements.
Public scrutiny: One weak or vague statement can damage brand trust overnight, and companies that have demonstrated a lack of action are facing more scrutiny.
Supply chain risk is more visible than ever: From forced labour in raw materials to recruitment practices in manufacturing hubs, modern slavery risks are no longer as hidden as they used to be.
Now is the time to build a strong foundation for resilient, ethical supply chains by strengthening governance, mapping high‑risk tiers of your value chain, and embedding practical controls such as supplier screening, worker‑voice mechanisms, and on‑the‑ground verification.
Follow our modern slavery blog series, where we break down human rights compliance regulations across different jurisdictions and what they mean for your due diligence obligations.
Further resources from BSI Consulting
Read Kimberly’s first blog in her modern slavery series: What Modern Slavery Means for Today’s Supply Chains
Read BSI Consulting's e-book From policy to practice: Eradicating modern slavery, fighting worker exploitation throughout global supply chains.
