On 30 June 2026, the government introduced its Immigration and Asylum Bill, bringing with it the most significant overhaul of modern slavery reporting rules since the original legislation was passed over a decade ago.

For thousands of businesses and public bodies across the country, the changes, if passed, will mean new obligations, tougher scrutiny, and the real prospect of financial penalties for the first time.

What the Bill proposes

Financial penalties: A first

The most significant change is the introduction, for the first time, of financial penalties for non-compliance. The Secretary of State would be empowered to make regulations imposing a penalty on any organisation that, ‘without reasonable excuse’, fails to meet its obligations. The penalty could not exceed the greater of £1 million or 1% of the organisation's total turnover  and only one penalty could be imposed per statement per financial year.

Mandatory content

If passed, this is a fundamental change. It would transform the existing generic duty to describe steps taken to tackle modern slavery, with businesses able to exercise discretion over how and whether they describe those steps, to specific reporting duties under mandatory disclosure topics, supported by a ‘comply or explain’ approach.

In practical terms, modern slavery statements would need to address, on a mandatory basis: 

• The organisation's structure. 
• Operations and supply chains. 
• The parts of its operations and supply chains presenting a risk of slavery or trafficking, along with steps taken to assess and reduce that risk.
• Its policies and due diligence processes addressing slavery and trafficking.
• Training made available both to its own staff and, so far as reasonably ascertainable, to workers within its supply chains.
• An assessment of the effectiveness of the organisation's efforts during the year, measured against indicators of its choosing.

Crucially, where any of these areas are left blank, organisations will not be able to simply say nothing. They will have to explain why, a ‘comply or explain’ mechanism that places the burden squarely on the organisation.

Public bodies 

The obligation to prepare a modern slavery statement is proposed to be expressly extended beyond commercial organisations to public authorities whose budgets exceed a threshold to be fixed in regulations. The Bill defines 'public authority' broadly, capturing any person with functions of a public nature.

Once public authorities are subject to their own reporting obligations, government procurement processes are expected to incorporate more rigorous supply chain transparency requirements. Companies that supply to the public sector should take note.

Signing off: A new personal responsibility

A new requirement would oblige the individual signatory to declare that the statement is accurate to the best of their knowledge and belief, and to record the dates of approval and signature.

This introduces a meaningful element of personal accountability for senior leaders, raising the stakes for those who sign off on statements without ensuring they are accurate and well-evidenced.

Stricter deadlines and electronic submission

The Bill makes it mandatory that organisations publish and submit their statement as soon as reasonably practicable after the end of the financial year to which it relates, and no later than six months after the end of that financial year.

The government also seems likely to mandate the uploading of statements to its existing modern slavery statement registry.

The international picture

These proposed domestic changes do not sit in isolation. The EU's Forced Labour Regulation (FLR), due to take effect from 14 December 2027, will prohibit the placing or export of products tainted by forced labour on the EU market.

Unlike the Modern Slavery Act, the FLR is not a reporting regime, it operates as an outright product ban, applying to all companies placing products on or exporting from the EU market. UK businesses with European operations or supply chains will need to think about both regimes simultaneously.

What is not in the bill

Notably, the Bill does not go so far as to mandate human rights due diligence on supply chains, despite previous recommendations from the House of Commons Joint Committee on Human Rights and the Independent Anti-Slavery Commissioner.

The government is still considering whether to mandate human rights due diligence as part of its broader review into responsible business conduct and has not yet formally confirmed its approach. 

What happens next and what you should do

The second reading of the Immigration and Asylum Bill in the House of Commons commenced on 13 July 2026, and the proposals are considered to have a realistic prospect of enactment. Even if Royal Assent is granted, further secondary legislation will be required before the new rules come into force, meaning any new laws may not be in place until 2027.

In the meantime, organisations would be well advised to review their existing modern slavery statements against the proposed new content requirements:

• Identify gaps, particularly around risk mapping, due diligence and effectiveness. 
• Ensure that board members are aware of the potential for increased personal accountability.

For businesses supplying to the public sector, greater supply chain scrutiny from contracting authorities should also be anticipated. The era of discretionary, consequence-free modern slavery reporting is coming to an end. Please contact our specialist Modern Slavery lawyers to discuss your organisation's circumstances and next steps.