Ten years of the Modern Slavery Act: renewed focus on business responsibility

What is the update?

On 24 March 2025, the Home Office published its updated Transparency in Supply Chains (TISC) guidance (the Guidance), offering detailed recommendations to assist organisations in complying with their obligations under Section 54 of the Modern Slavery Act 2015 (the Act).

When the Act came into force 10 years ago, it was praised as a "world-leading" piece of legislation, reflecting the UK's firm stance against the crimes of slavery, servitude, forced labour, and human trafficking. Section 54 introduced one of the first mandatory requirements for large businesses – with a turnover of £36m or more and carrying out business in the UK - to publish annual statements, to address slavery in their operations and supply chains.

Despite its promising start, in the decade that has followed, the Act has received wide spread criticism due to its alleged 'lack of teeth', with calls for strengthened guidance and, more recently, the House of Lords reporting that the Act is "too limited to have significant practical impact". 

This raises the question of whether the refreshed Guidance makes any significant changes to address the perceived shortfalls of the Act. At the Guidance launch event, the Minister for Safeguarding and Violence Against Women and Girls, Jess Phillips, welcomed  the return of the modern slavery brief to her role's remit, emphasising that slavery is "not just an evil of the past" and warning that organisations failing to identify risks are "probably not looking hard enough".

What are the key changes?

The Guidance pushes organisations to adjust their perspective of their section 54 obligations, moving beyond box-ticking towards wider transparency, and seeking compliance with not just the letter but also "the spirit" of section 54. Some of the key changes to the Guidance include:

• The Government Registry: Since its launch in March 2021, organisations have been encouraged to upload their statements to the government's Modern Slavery Statement Registry, centralising statements into one place and inviting public scrutiny. The Guidance now includes express reference to the registry and renews this call to action, despite stopping short of introducing a mandatory requirement to upload.
• Two-tier system of disclosures: The Guidance has introduced a two-tier system in relation to the recommended statement disclosures, distinguishing between organisations drafting their statements for the first time and organisations that are more familiar with the reporting requirements. The latter group is expected to provide deeper insights and to demonstrate progress over time, continuously improving their practices.
• Focus on Environmental, Social and Governance (ESG): The Guidance cites the impact of modern slavery on market positioning, procurement processes and insurance premiums, while also referencing how investors are increasingly focused on wider ESG factors (a fact demonstrated by those groups in attendance at the Guidance launch event). It recommends a unified strategy for risk mapping, due diligence and remediation to streamline compliance and address diverse stakeholder expectations.
• Individual statements for group structures: The Guidance has clarified that while it remains permissible for a parent company to produce a single statement that its in-scope subsidiaries can also use, if the various organisations within a group structure operate across different sectors (and therefore attract different risks and responses) it is best practice for each in-scope organisation to produce their own tailored statement rather than relying on the parent company's.
• Changing attitudes: The Minister has expressed her desire to see attitudes towards the section 54 disclosure obligations change from an avoidance or deniability approach, to one of increased accountability and knowledge-sharing. The Guidance warns that organisations that ignore or deny the presence of modern slavery risks in their supply chains are "highly unlikely to have conducted effective risk assessments and due diligence", while responsible organisations are those which "acknowledge the risks".

What comes next?

Despite the positive changes to the Guidance outlined above, it stops short of introducing new mandatory obligations that might provide meaningful remedy to the existing criticisms of the Act. Many of the new recommendations remain voluntary and, although failure to comply with section 54 risks reputational damage and exclusion from public contracts, the UK's anti-modern slavery regime still fails to impose truly meaningful penalties. It's notable that while the Home Secretary has the power to bring civil proceedings, no injunctions have been issued to date, and the Guidance does not move the dial on this point.

Ultimately, the Guidance's remit is limited by the shortfalls of the Act and real progress will require legislative reform. The return of the modern slavery brief to the Safeguarding Minister suggests a renewed government focus and intent to drive meaningful change.

RPC will continue to share any updates regarding the MSA and TISC guidance and share new information as it becomes available. Please get in touch with the authors listed here if we can provide any advice in this area.