By 
T S, Unsplash, 2023.
A recent update of the statutory guidance on the Modern Slavery Act 2015 by the UK Home Office is focused on improving corporate due diligence in combating forced labour and human trafficking.
The announcement came on March 25th, 2025, with the updates including clarification on the requirements of Transparency in Supply Chains (TISC). It now requires commercial entities that have turnover of at least £36 million annually to issue modern slavery statements covering companies’ progress on due diligence efforts in combating human trafficking and slavery throughout the operations and supply chains.
When first adopted in 2015, the act was seen as a huge step towards corporate compliance with human rights. However, more recently, many businesses have either failed to meet the reporting requirements or provided insufficient information on their supply chains. Article 54 on TISC, which was initially adopted to ensure corporate accountability through public pressure and leverage consumers, has also failed to have any effect. Unfortunately, without mandatory penalties or enforcement, the risks of noncompliance remain high.
Many human rights organisations have warned the UK government of weak enforcement of Article 54 of the Modern Slavery Act. It has been actively criticised for merely encouraging corporations to voluntarily disclose the initiatives they are taking to prevent any exploitation without any concrete measures.
Even after updating the regulation, the UK’s approach to corporate due diligence remains voluntary. The European Union, on the other hand, has passed a directive on human rights due diligence and corporate compliance, which obligates member states to adopt it into their national legislations. Countries like Germany, Norway, and the Netherlands have introduced financial penalties for companies that fail to comply with human rights due diligence. This development reiterates the need for global action towards stricter corporate accountability. Meaningful changes to combat modern slavery practices like forced labour and human trafficking are only possible through stricter measures like financial penalties and mandatory compliance.
Rt Revd Vivienne Faull, the Bishop of Bristol, has also expressed concerns over exploitative practices by businesses and said that the Modern Slavery Act “must keep pace with changes to business practice” (Walsh, 2025). Although the updates on the guidance might bring some improvements in corporate compliance, the lack of mandatory enforcement raises doubts about its effectiveness.
The International Bar Association’s Human Rights Institute (IBAHRI) has further advised the UK to adopt a ‘‘multifaceted approach’’ in tackling modern slavery. This approach includes mandatory reporting by corporations and the introduction of financial penalties to ensure that the UK keeps up with global initiatives that challenge issues of modern slavery. A stronger parliamentary initiative is crucial in ensuring corporations are held accountable for human rights violations.
Sources and further readings:
IBAHRI calls for urgent action to abolish modern slavery on the ten-year anniversary of the UK’s Modern Slavery Act. International Bar Association. March 25, 2025. <https://www.ibanet.org/IBAHRI-calls-for-urgent-action-to-abolish-modern-slavery-on-ten-year-anniversary-of-the-UKs-Modern-Slavery-Act> accessed April 2, 2025.
It’s not enough for companies to be aware of modern slavery—UK needs to prevent it. Reuters. March 28, 2025. <https://www.reuters.com/sustainability/society-equity/its-not-enough-companies-be-aware-modern-slavery-uk-needs-prevent-it-2025-03-28/> accessed April 2, 2025.
Law should address uneven compliance over modern slavery, Bishop of Bristol tells Lords. Church Times. April 2, 2025. <https://www.churchtimes.co.uk/articles/2025/4-april/news/uk/law-should-address-uneven-compliance-over-modern-slavery-bishop-of-bristol-tells-lords> accessed April 2, 2025.
Modern Slavery Act 2015. <https://www.legislation.gov.uk/ukpga/2015/30/contents.> Accessed April 2, 2025.
Modern Slavery Act Compliance: Written Evidence. UK Parliament. March 2025. <https://committees.parliament.uk/writtenevidence> Accessed April 2, 2025.
UK government releases updated guidance on modern slavery in supply chains. Walk Free. March 25, 2025. <https://www.walkfree.org/news/2025/uk-government-releases-updated-guidance-on-modern-slavery-in-supply-chains/> Accessed April 2, 2025.
Updated UK Modern Slavery Act guidance published: An in-depth look at the statement. Ropes & Gray LLP. March 25, 2025. <https://www.ropesgray.com/en/insights/viewpoints/102k6wu/updated-uk-modern-slavery-act-guidance-published-an-in-depth-look-at-the-statem> Accessed April 2, 2025.
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