Global Modern Slavery Legislation

Transparency in Supply Chains Act 2010

The United States addresses forced labour through a combination of corporate disclosure obligations and border enforcement rather than a single nationwide modern slavery reporting regime. Its legislative framework is designed to increase transparency within supply chains while preventing products linked to exploitative labour practices from entering the U.S. market.

One part of this framework is the California Transparency in Supply Chains Act, which requires qualifying businesses with annual worldwide revenue exceeding USD 100 million to publicly disclose how they identify and manage slavery and human trafficking risks throughout their operations and supply chains. At the border, the Tariff Act empowers U.S. Customs and Border Protection to detain goods suspected of being produced with forced or indentured labour by issuing Withhold Release Orders. These import restrictions are further strengthened by the Uyghur Forced Labour Prevention Act, which presumes products originating from China's Xinjiang region are made with forced labour unless sufficient evidence is provided to demonstrate otherwise.

Modern Slavery Act 2015

The United Kingdom was one of the first countries to establish dedicated legislative reporting requirements for modern slavery through the Modern Slavery Act 2015. In addition to introducing tougher criminal offences relating to slavery and human trafficking, the Act strengthened support for victims and created the role of the Anti Slavery Commissioner to promote a coordinated national response.

The legislation requires commercial organisations with annual turnover exceeding £36 million to publish a modern slavery statement describing the systems and actions used to identify, assess, and manage modern slavery risks across their operations and supply chains. Although the Act does not currently impose financial penalties for failing to report, the United Kingdom has proposed reforms aimed at strengthening the reporting framework and bringing it more closely into line with Australia's model.

Modern Slavery Act 2018

Australia established a national modern slavery reporting regime through the Modern Slavery Act 2018. The legislation requires entities with consolidated annual revenue of at least AUD 100 million to prepare a modern slavery statement for each reporting period, explaining how modern slavery risks are identified, assessed, and addressed within their operations and supply chains.

The Act promotes transparency by requiring organisations to describe identified risks, actions taken, consultation processes, and how the effectiveness of those actions is assessed. Statements may also outline governance arrangements, due diligence activities, and risk management processes. They are published on the Modern Slavery Statements Register, administered by the Attorney-General’s Department.

The Act does not currently impose financial penalties for reporting failures, although the Minister may require remedial action and publicly identify non-compliant entities. In July 2026, the Australian Government announced proposed civil penalties for breaches of existing reporting requirements and a new criminal offence for companies that fail to prevent modern slavery in their supply chains. These reforms remain under consultation and are not yet in force.

Draft Legislation

New Zealand is developing a proposed legislative framework that would introduce modern slavery reporting and due diligence obligations for businesses. Released by the Government in April 2022, the proposal is intended to improve corporate transparency and strengthen efforts to identify and prevent worker exploitation throughout business operations and supply chains.

Under the proposed model, medium and large organisations would be required to publicly report on how they manage modern slavery risks. The largest businesses would also have additional due diligence responsibilities, requiring them to identify, assess, prevent, and mitigate modern slavery risks across both their New Zealand operations and their global supply chain activities.

The Forced Labor Regulation (FLR)

In 2024, the European Union introduced the Forced Labour Regulation to remove products linked to forced labour from the European market. Instead of requiring organisations to publish modern slavery reports, the regulation targets the movement of goods by preventing products associated with exploitative labour practices from being imported, sold, or exported within the European Union.

The framework gives national competent authorities the power to investigate products where forced labour is suspected. Where a connection is confirmed, authorities may require the goods to be withdrawn from the market, prohibit their import or export, and prevent any further distribution. Organisations that breach the regulation may also face a range of enforcement measures, including financial penalties, regulatory sanctions, and restrictions on participation in public procurement.

Corporate Duty of Vigilance Law of 2017

France's Corporate Duty of Vigilance Law requires large companies that meet the applicable employee thresholds to implement formal human rights and environmental due diligence. Rather than focusing solely on a company's own activities, the legislation requires organisations to prepare and publish a vigilance plan addressing risks connected to subsidiaries, contractors, suppliers, and other established business relationships.

Compliance is enforced through the courts rather than through a reporting regulator. Organisations that fail to meet their obligations may be subject to legal proceedings, court orders requiring compliance, and financial liability where legislative breaches or resulting harm are established.

Supply Chain Due Diligence Act

Germany has introduced mandatory human rights due diligence requirements through the Supply Chain Due Diligence Act, with implementation occurring in stages. The legislation first applied to organisations employing more than 3,000 people before expanding in 2024 to include companies with a workforce of more than 1,000 employees.

The Act requires organisations to integrate human rights risk management into their day to day operations rather than simply reporting on their activities. Covered businesses must identify potential risks, implement preventive and corrective measures, establish procedures for addressing human rights concerns, and regularly review the effectiveness of their due diligence systems. These obligations cover issues including forced labour, child labour, and other human rights abuses. Organisations that fail to comply may face significant financial penalties and restrictions on access to public procurement opportunities.