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Oversight Institute
Category: Regulatory Frameworks

UK Modern Slavery Act

Also known as: MSA, Modern Slavery Act 2015, UK Modern Slavery Act 2015
Simply put

The UK Modern Slavery Act is a United Kingdom law passed in 2015 that aims to combat modern slavery and human trafficking, including within business supply chains. It consolidated earlier UK offences relating to slavery and trafficking into a single piece of legislation. It also introduced transparency expectations that require certain businesses to disclose the steps they take to address modern slavery in their operations and supply chains.

Formal definition

The Modern Slavery Act 2015 is UK legislation designed to combat modern slavery and human trafficking, consolidating previously separate offences relating to trafficking and slavery. For third-party and supply chain risk practitioners, its most relevant feature is the supply chain transparency provision, which requires in-scope organisations to publish a statement describing the actions taken to identify and address modern slavery risk within their operations and supply chains. The statement is a disclosure and transparency mechanism rather than a certification of compliance or an assurance that modern slavery is absent; it does not, by itself, mandate specific due diligence outcomes or independent verification of the actions described. As a UK statute, its requirements are jurisdiction-specific and should not be assumed equivalent to modern slavery or human rights due diligence regimes in other regions, which may impose differing or more prescriptive obligations.

Why it matters

For third-party and supply chain risk practitioners, the UK Modern Slavery Act matters because it embeds modern slavery and human trafficking risk into the formal compliance obligations of in-scope businesses. Rather than treating labour exploitation as a purely ethical concern, the Act's supply chain transparency provision requires certain organisations to publish a statement describing the steps they take to identify and address modern slavery within their own operations and their supply chains. This brings human rights risk into the same governance conversation as financial, operational, and security risk, and it typically requires practitioners to extend their diligence beyond direct suppliers toward the labour practices embedded in extended supply networks.

The practical significance lies in what the statement is and is not. The required disclosure is a transparency mechanism intended to make a business's actions visible; it is not a certification that modern slavery is absent, nor an independent verification of the measures described. A published statement can satisfy the disclosure expectation while still leaving material risk unaddressed, particularly beyond the first tier of suppliers where visibility is often limited. Practitioners should therefore treat a counterparty's modern slavery statement as one input into an assessment rather than as assurance of a clean supply chain.

Because the Act is UK legislation, its requirements are jurisdiction-specific. Organisations operating across regions should not assume that publishing a UK statement satisfies modern slavery or broader human rights due diligence obligations elsewhere, as other regimes may impose differing or more prescriptive requirements. Managing this term well means understanding the boundary between disclosure and substantive due diligence, and recognising that the Act sets a transparency expectation rather than mandating specific outcomes.

Who it's relevant to

Compliance and Legal Teams
Compliance and legal functions in in-scope UK organisations are responsible for determining applicability, preparing the required transparency statement, and ensuring disclosures accurately reflect the actions the business takes. They also need to distinguish the Act's UK-specific requirements from modern slavery and human rights due diligence obligations in other jurisdictions, which may be differing or more prescriptive.
Third-Party and Supply Chain Risk Managers
Risk practitioners use the Act as a driver for extending diligence into labour and human rights risk across the supply chain. They typically treat a supplier's published statement as one input rather than as assurance, given that it is a disclosure rather than a verified outcome and that visibility often diminishes beyond the first tier of suppliers.
Procurement and Supplier Onboarding Teams
Procurement teams may incorporate modern slavery expectations into onboarding, supplier codes of conduct, and contractual terms. They should recognise that a counterparty holding a modern slavery statement demonstrates disclosure, not independent verification that modern slavery is absent from that supplier's operations or lower tiers.
ESG and Sustainability Functions
ESG and sustainability teams align modern slavery disclosure with broader responsible sourcing and human rights commitments. They should be mindful that the Act sets a transparency expectation and does not, by itself, mandate specific due diligence outcomes, so substantive programmes are needed to move beyond disclosure toward actual risk reduction.

Inside MSA

Transparency in Supply Chains Provision
A provision within the Act requiring certain commercial organizations meeting a defined turnover threshold and carrying on business in the UK to prepare and publish an annual statement describing the steps taken to address modern slavery and human trafficking in their operations and supply chains. The specific turnover threshold is set in secondary legislation, and organizations should confirm the current figure rather than assume it.
Modern Slavery Statement
The annual disclosure that in-scope organizations must publish and approve at the appropriate governance level. The Act does not mandate a specific set of actions; it requires disclosure of the steps taken, or a statement that no steps were taken. It is fundamentally a transparency and disclosure obligation rather than a prescriptive control standard.
Suggested Disclosure Areas
Categories the statement may address, such as organizational structure and supply chains, relevant policies, due diligence processes, risk assessment and management, training, and effectiveness measures. These are typically framed as recommended content rather than strictly mandated line items, so coverage varies across organizations.
Scope and Applicability
The transparency obligation applies to qualifying commercial organizations that supply goods or services and carry on business in the UK, based on turnover criteria. It does not extend to every organization operating in the UK, and it is distinct from the Act's separate criminal offense provisions relating to slavery, servitude, forced labor, and human trafficking.
Relationship to Broader Due Diligence
The Act intersects with third-party and supply chain risk management because addressing modern slavery typically requires visibility into supplier labor practices. However, the Act itself centers on disclosure of steps taken and does not prescribe a specific due diligence methodology, monitoring frequency, or depth of tier coverage.

Common questions

Answers to the questions practitioners most commonly ask about MSA.

Does the UK Modern Slavery Act require companies to eliminate modern slavery from their supply chains?
No. The Act's transparency provisions require certain organisations to publish an annual statement describing the steps they have taken (if any) to address modern slavery in their operations and supply chains. It does not mandate that a company achieve a slavery-free supply chain, nor does it prescribe specific due diligence measures. A statement that discloses limited or no action can still satisfy the publication requirement, even though it may attract reputational or stakeholder criticism. The obligation is one of disclosure, not of guaranteed outcomes.
Is a published modern slavery statement the same as verified compliance or proof that a supply chain is free of forced labour?
No. A statement is a self-reported disclosure of an organisation's stated approach; it is not independent verification, certification, or assurance that forced labour is absent. It reflects what the organisation chooses to report about its policies, processes, and steps taken, and does not by itself confirm conditions in lower-tier suppliers or beyond the first tier. Treating a statement as evidence of a controlled or slavery-free supply chain conflates attestation with independent validation.
How do we determine whether our organisation falls within the scope of the reporting requirement?
Scope typically turns on whether an organisation carries on business, or part of a business, in the relevant jurisdiction, supplies goods or services, and meets the applicable turnover threshold. Because thresholds and qualifying criteria are set by the legislation and any implementing guidance, organisations generally confirm their status against the current statutory text rather than relying on general rules of thumb. Group structures may raise questions about whether parent or subsidiary entities report separately or jointly, so legal review is common where corporate structure is complex.
What content is typically included in a modern slavery statement?
Statements commonly describe the organisation's structure, business, and supply chains; relevant policies; due diligence processes; the parts of the business and supply chains where risk is identified and how it is assessed and managed; any training provided; and how effectiveness is measured. These are areas the legislation identifies as ones a statement may cover, rather than a rigid mandatory template. In practice, the depth and quality of disclosure vary considerably between organisations.
How does the modern slavery statement fit alongside broader third-party and supply chain risk activities?
The statement is a disclosure output, whereas the underlying work, supplier risk assessment, due diligence, ongoing monitoring, and remediation, forms part of a wider programme. Many programmes integrate modern slavery risk into existing onboarding and monitoring processes, though visibility often diminishes beyond the first tier, which limits how much lower-tier risk can be assessed and disclosed. The statement should reflect actual activities rather than drive them, and point-in-time disclosures can become stale as supplier relationships change.
What approval and publication steps are generally expected for a statement?
Statements are typically subject to internal sign-off and published so they are accessible, often via the organisation's website, and refreshed on an annual basis. Approval and signature by an appropriate level of the organisation is commonly part of the process. Because specific approval, signature, and publication expectations are set out in the legislation and associated guidance, organisations generally align their process with the current statutory requirements rather than assuming a single fixed procedure applies across all regions or sectors.

Common misconceptions

The Act requires organizations to eliminate modern slavery from their supply chains.
The transparency provision is primarily a disclosure obligation. It requires in-scope organizations to publish an annual statement describing the steps taken, and it permits a statement that no steps were taken. It does not mandate specific outcomes or guarantee that modern slavery has been removed from any supply chain.
Publishing a modern slavery statement demonstrates that an organization has verified conditions across all supplier tiers.
Statements commonly reflect steps taken at the direct supplier level and often rely on self-reported information and policy commitments. Visibility beyond the first tier is frequently limited, and a published statement does not by itself constitute independent verification of labor conditions across the extended supply chain.
The UK Modern Slavery Act sets a single global standard for supply chain human rights disclosure.
It is a UK measure with jurisdiction-specific applicability based on carrying on business in the UK and meeting turnover criteria. Other jurisdictions have their own modern slavery, forced labor, or human rights due diligence regimes with differing scope, thresholds, and obligations, so requirements should be assessed per applicable jurisdiction.

Best practices

Confirm applicability against the current turnover threshold and UK business-nexus criteria in the applicable secondary legislation rather than assuming in-scope or out-of-scope status.
Treat the statement as a disclosure of substantive steps actually taken, ensuring described policies, due diligence, and risk assessment activities are genuinely in place and approved at the appropriate governance level.
Integrate modern slavery risk into broader third-party and supply chain risk assessment processes, tiering suppliers by exposure rather than relying on a single point-in-time questionnaire.
Recognize the limits of self-reported supplier information and, where risk warrants, supplement attestations with independent verification rather than treating a signed policy commitment as assurance.
Extend visibility efforts beyond direct suppliers where feasible, while acknowledging in the statement the practical limits of insight into lower tiers.
Coordinate the UK statement with obligations under other jurisdictions' modern slavery and human rights due diligence regimes to avoid presenting one regime's disclosure as satisfying all applicable requirements.
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