How businesses can meet the UK’s new modern slavery transparency rules

A decade after the introduction of the Modern Slavery Act 2015, the UK government has adopted a tougher stance on modern slavery.

On 24 March 2025, the Home Office released its revised Transparency in Supply Chains (TISC) Guidance, setting higher expectations for businesses to root out forced labour, human trafficking, and exploitation in their operations.

This isn’t just another compliance update—it’s a wake-up call for companies that have treated their annual Modern Slavery Statement as a box-ticking exercise. The message is clear: vague commitments are no longer sufficient. Businesses must now prove they’re taking real, measurable action.

So, what’s changed—and how can companies stay ahead?

Why the guidance needed an overhaul

When the Modern Slavery Act first came into force in 2015, it was groundbreaking. For the first time, large companies (those with a global turnover of over £36 million) had to publicly disclose what they were doing to tackle slavery in their supply chains.

Over time, critics argued that many businesses were doing the bare minimum, publishing generic statements with minimal substance. Some even copied and pasted from previous years without making real improvements.

The updated guidance, shaped by input from businesses, NGOs, trade unions, and academics, aims to fix this. It pushes companies to move beyond lip service and adopt genuine, proactive measures.

Key changes in the guidance

1. Moving from ‘paper compliance’ to ‘meaningful action’

The Home Office is clamping down on boilerplate statements. Companies must now:

• show evidence of risk assessments and due diligence;
• track year-on-year progress—what has actually improved?; and
• engage directly with high-risk suppliers rather than relying on policies alone.

2. Stronger focus on supply chain transparency

Many businesses still struggle to monitor beyond their Tier 1 suppliers. The new guidance urges businesses to dig deeper into their supply chains:

• Map out subcontractors and raw material sources—where are the hidden risks?
• Leverage emerging technologies such as blockchain or AI-driven audits to monitor and verify labour conditions more effectively.
• Partner with NGOs and trade unions for independent verification.

3. Board-level accountability

While the act doesn’t impose criminal penalties for non-compliance (yet), directors are under increasing pressure. Investors, consumers, and regulators now expect:

• Clear oversight—who at the executive level owns this issue?
• Publicly measurable targets (e.g., “We audited 100% of high-risk suppliers”).
• Whistleblower protections so workers can report abuses safely.

What these changes mean for businesses

For legal & compliance teams

• Conduct a full supply chain review—identify gaps in current policies;
• Update Modern Slavery Statements to reflect specific actions, not just intentions; and
• Train procurement teams to spot red flags (e.g., sudden subcontracting, lack of worker contracts).

For procurement & supply chain managers

• Demand transparency from suppliers—include anti-slavery clauses in contracts;
• Prioritise high-risk sectors (e.g., textiles, agriculture, construction); and
• Consider third-party audits—self-assessment isn’t always enough.

For directors & investors

• Treat modern slavery as a strategic risk, not just a legal obligation;
• Align with global standards (UN Guiding Principles, OECD Due Diligence); and
• Prepare for future regulations—the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) may soon affect UK firms too.

The bigger picture: why this matters

Beyond legal compliance, businesses that take this seriously will not only meet legal requirements but also:

• Reduce reputational risks (no one wants to be linked to forced labour);
• Win investor confidence (ESG funds scrutinise modern slavery efforts); and
• Build stronger supplier relationships (ethical sourcing attracts better partners).

The revised guidance isn’t just about avoiding bad PR—it’s about fostering fairer, more sustainable supply chains that benefit businesses, workers, and communities alike.

Next steps for your business

• Review last year’s statement—does it meet the new expectations?;
• Conduct a risk assessment—where are your biggest exposure points?; and
• Engage leadership—ensure the board understands the stakes.