Fashionable slavery stays a world disaster, and it’s getting worse. An estimated 50 million individuals worldwide reside in fashionable slavery, together with 28 million in compelled labour and 22 million in compelled marriage, in response to the Worldwide Labour Group. That quantity has risen sharply on account of battle, local weather change, and the financial fallout from COVID-19. Governments and media are ramping up scrutiny: in December 2024, a BBC investigation revealed that UK supermarkets could also be sourcing from suppliers linked to compelled labour, whereas that very same month, the EU’s compelled labour ban got here into impact, barring items made with compelled labour from coming into the one market. In the meantime, international locations together with Australia, France, Germany, Norway, and Switzerland already require corporations to actively report on their efforts to fight compelled labour.
In March 2025, the UK House Workplace revealed a long-awaited replace to fashionable slavery steering in its Transparency in Provide Chains statutory steering below the Fashionable Slavery Act. The refresh to the steering is the primary vital replace in practically a decade, providing companies a a lot clearer image of what significant disclosure seems like, regardless that the underlying authorized responsibility stays unchanged.
With Parliament set to return in September, and recent strain mounting for reform, it’s time to revisit the March steering, not as a result of something has modified legally since then, however as a result of this steering more and more seems like a precursor to legislative change. Whereas the legislation hasn’t modified, the route of journey is obvious, so now could be the time for companies to tune in.
The legislation hasn’t modified, however expectations have
The brand new steering marks a notable shift in tone from the federal government. It strikes past box-ticking and encourages corporations to concentrate on effectiveness, not simply course of. It pushes for year-on-year enchancment. It gives extra construction, extra readability, and clearer expectations, particularly for advanced company teams. In brief, it’s about what’s coming subsequent.
Why this issues now: A September shake-up?
Right here’s what’s modified since the steering was revealed:
- In July 2025, the Joint Committee on Human Rights issued a main report calling for:
- Obligatory human rights due diligence
- Stronger civil legal responsibility for hurt
- An import ban on items linked to compelled labour
The federal government should reply inside 60 days, i.e., simply after Parliament resumes in September.
- In March, the Enterprise & Commerce Committee warned that the UK dangers turning into a “dumping floor” for items linked to exploitation, and really helpful necessary fashionable slavery reporting with enforcement powers.
- The Impartial Anti-Slavery Commissioner’s 2024–25 report, revealed in Could, backed legislative reform, calling for a brand new fashionable slavery technique, necessary due diligence, and coordinated enforcement.
Taken collectively, these developments present that the political local weather is shifting quick. And that March steering? It’s seemingly step one in a broader compliance overhaul.
The route of journey: From transparency to accountability
For years, fashionable slavery compliance has been constructed on a mannequin of transparency with out enamel: Because the Fashionable Slavery Act got here into drive, compliance with the reporting responsibility has largely operated with out energetic enforcement. Whereas the legislation permits the House Workplace to hunt a court docket injunction in opposition to non-compliant corporations, this energy has by no means been used, and there are at the moment no direct monetary or legal penalties for failing to publish a press release.
However now, it seems like that’s altering.
The brand new steering, and the political momentum behind it, recommend that the UK is lastly shifting nearer to the EU mannequin, the place companies are anticipated to conduct correct human rights and environmental due diligence, backed by enforcement powers and civil legal responsibility.
On the similar time, broader authorized reforms are tightening the online: the Financial Crime and Company Transparency Act (ECCTA) has already expanded company legal responsibility for fraud and different financial crimes dedicated by senior managers, whereas the Crime and Policing Invoice proposes extending that very same legal responsibility mannequin to all legal offences, doubtlessly together with fashionable slavery and labour exploitation. Prosecutors are more and more centered on provide chain failures — and this mixture of political strain, up to date steering, and increasing authorized frameworks indicators a transparent shift from voluntary transparency to actual accountability.
What ought to companies do now?
Although the legislation hasn’t modified (but) companies ought to deal with this as a sign to behave, not wait. With the expectations round fashionable slavery reporting are shifting, right here’s how one can get forward:
- Reassess your fashionable slavery assertion
Does it mirror precise danger evaluation, real-world affect, and year-on-year enchancment? - Map your provide chain
Particularly for items linked to high-risk areas or industries. Be able to display traceability. - Align inside groups
Procurement, authorized, compliance, and sustainability ought to work collectively to ship significant due diligence. - Have interaction suppliers meaningfully
Transfer past questionnaires. Assume audits, coaching, and long-term relationship-building. - Look past the UK
For those who function internationally, begin aligning with the EU’s Company Sustainability Due Diligence Directive (CSDDD)—it’s a preview of the place the UK could also be heading. - Get forward of enforcement
Strengthen governance and controls as if the registry, penalties, and reporting necessities had been already legislation, as a result of they quickly could be.
The House Workplace’s fashionable slavery steering might not carry the drive of legislation but, nevertheless it’s a transparent warning shot.
As we head into the following parliamentary time period, the route of journey is obvious — expectations are rising, scrutiny is intensifying, and the times of passive compliance are numbered. For companies, that is the second to maneuver past the minimal and embed significant, proactive accountability into each stage of their provide chain.
Ensure your fashionable slavery compliance is updated and prepared for the modifications forward.
Fashionable slavery stays a world disaster, and it’s getting worse. An estimated 50 million individuals worldwide reside in fashionable slavery, together with 28 million in compelled labour and 22 million in compelled marriage, in response to the Worldwide Labour Group. That quantity has risen sharply on account of battle, local weather change, and the financial fallout from COVID-19. Governments and media are ramping up scrutiny: in December 2024, a BBC investigation revealed that UK supermarkets could also be sourcing from suppliers linked to compelled labour, whereas that very same month, the EU’s compelled labour ban got here into impact, barring items made with compelled labour from coming into the one market. In the meantime, international locations together with Australia, France, Germany, Norway, and Switzerland already require corporations to actively report on their efforts to fight compelled labour.
In March 2025, the UK House Workplace revealed a long-awaited replace to fashionable slavery steering in its Transparency in Provide Chains statutory steering below the Fashionable Slavery Act. The refresh to the steering is the primary vital replace in practically a decade, providing companies a a lot clearer image of what significant disclosure seems like, regardless that the underlying authorized responsibility stays unchanged.
With Parliament set to return in September, and recent strain mounting for reform, it’s time to revisit the March steering, not as a result of something has modified legally since then, however as a result of this steering more and more seems like a precursor to legislative change. Whereas the legislation hasn’t modified, the route of journey is obvious, so now could be the time for companies to tune in.
The legislation hasn’t modified, however expectations have
The brand new steering marks a notable shift in tone from the federal government. It strikes past box-ticking and encourages corporations to concentrate on effectiveness, not simply course of. It pushes for year-on-year enchancment. It gives extra construction, extra readability, and clearer expectations, particularly for advanced company teams. In brief, it’s about what’s coming subsequent.
Why this issues now: A September shake-up?
Right here’s what’s modified since the steering was revealed:
- In July 2025, the Joint Committee on Human Rights issued a main report calling for:
- Obligatory human rights due diligence
- Stronger civil legal responsibility for hurt
- An import ban on items linked to compelled labour
The federal government should reply inside 60 days, i.e., simply after Parliament resumes in September.
- In March, the Enterprise & Commerce Committee warned that the UK dangers turning into a “dumping floor” for items linked to exploitation, and really helpful necessary fashionable slavery reporting with enforcement powers.
- The Impartial Anti-Slavery Commissioner’s 2024–25 report, revealed in Could, backed legislative reform, calling for a brand new fashionable slavery technique, necessary due diligence, and coordinated enforcement.
Taken collectively, these developments present that the political local weather is shifting quick. And that March steering? It’s seemingly step one in a broader compliance overhaul.
The route of journey: From transparency to accountability
For years, fashionable slavery compliance has been constructed on a mannequin of transparency with out enamel: Because the Fashionable Slavery Act got here into drive, compliance with the reporting responsibility has largely operated with out energetic enforcement. Whereas the legislation permits the House Workplace to hunt a court docket injunction in opposition to non-compliant corporations, this energy has by no means been used, and there are at the moment no direct monetary or legal penalties for failing to publish a press release.
However now, it seems like that’s altering.
The brand new steering, and the political momentum behind it, recommend that the UK is lastly shifting nearer to the EU mannequin, the place companies are anticipated to conduct correct human rights and environmental due diligence, backed by enforcement powers and civil legal responsibility.
On the similar time, broader authorized reforms are tightening the online: the Financial Crime and Company Transparency Act (ECCTA) has already expanded company legal responsibility for fraud and different financial crimes dedicated by senior managers, whereas the Crime and Policing Invoice proposes extending that very same legal responsibility mannequin to all legal offences, doubtlessly together with fashionable slavery and labour exploitation. Prosecutors are more and more centered on provide chain failures — and this mixture of political strain, up to date steering, and increasing authorized frameworks indicators a transparent shift from voluntary transparency to actual accountability.
What ought to companies do now?
Although the legislation hasn’t modified (but) companies ought to deal with this as a sign to behave, not wait. With the expectations round fashionable slavery reporting are shifting, right here’s how one can get forward:
- Reassess your fashionable slavery assertion
Does it mirror precise danger evaluation, real-world affect, and year-on-year enchancment? - Map your provide chain
Particularly for items linked to high-risk areas or industries. Be able to display traceability. - Align inside groups
Procurement, authorized, compliance, and sustainability ought to work collectively to ship significant due diligence. - Have interaction suppliers meaningfully
Transfer past questionnaires. Assume audits, coaching, and long-term relationship-building. - Look past the UK
For those who function internationally, begin aligning with the EU’s Company Sustainability Due Diligence Directive (CSDDD)—it’s a preview of the place the UK could also be heading. - Get forward of enforcement
Strengthen governance and controls as if the registry, penalties, and reporting necessities had been already legislation, as a result of they quickly could be.
The House Workplace’s fashionable slavery steering might not carry the drive of legislation but, nevertheless it’s a transparent warning shot.
As we head into the following parliamentary time period, the route of journey is obvious — expectations are rising, scrutiny is intensifying, and the times of passive compliance are numbered. For companies, that is the second to maneuver past the minimal and embed significant, proactive accountability into each stage of their provide chain.
