Modern Slavery Compliance Is About to Get Teeth: Is Your Business at Risk?
- sophie9601
- Jul 23, 2025
- 2 min read
It’s hard to ignore that an estimated 25 million people worldwide are trapped in modern slavery through forced labour, trafficking and child exploitation. That’s nearly the entire population of Australia.
If your company earns more than $100 million in consolidated revenue, you're already required to report under the Modern Slavery Act 2018 (Cth). Failure to act could soon carry serious consequences as significant changes are on the horizon.
What You Need to Know Right Now
The current Modern Slavery Act requires businesses to submit an annual statement that outlines:
Your operations and supply chains
The risk of modern slavery in those areas
What you’re doing to address those risks (including due diligence, consultation, remediation)
Statements must be submitted within 6 months of the end of your financial year. There are no penalties yet, but that’s about to change.
The Government Review: What’s Changing?
Following a full review, the Albanese Government has backed 25 of 30 recommendations to strengthen the Act, including:
Civil penalties for non-compliance and false statements
Publishing a list of high-risk regions, industries and companies
Expanding mandatory reporting criteria
Notably, the $100 million threshold will remain (for now), but the Government has established an Anti-Slavery Commissioner who may revisit this.
Chris Evans, the Australian Anti-Slavery Commissioner, had recently written to business associations, legal firms and advisory firms, encouraging them to communicate the developments under the Act, including the introduction of penalties, to their members and clients.
Read his letter here.
What Are Our Peers Doing?
Australia is already behind the curve:
USA: Customs authorities have the power to detain and block the import of goods linked to forced labour.
EU: The Corporate Sustainability Due Diligence Directive requires large companies to identify and fix modern slavery, human rights and environmental risks across their operations and supply chains.
UK: Companies must publish detailed reports covering due diligence, risk assessments, KPIs, and staff training to combat modern slavery.
That means if you operate globally, your partners may start demanding more from you, even if Australian law doesn’t.
Most Businesses Aren’t Ready
90% of Australian businesses identified slavery risks in their supply chains
But 85% of statements failed to respond to actual or alleged slavery risks
However, the message from the Government Review is clear: modern slavery compliance is shifting from words to action.
What Now?
Most statements for FY24/25 are due by 30 December 2025. At Hikari Solutions, our legal and advisory team can help you:
Draft robust Modern Slavery Statements
Map supply chain risks and implement mitigation plans
Prepare for evolving due diligence expectations
Don't wait for penalties to bite. Get in touch with us now to stay compliant and ahead of the curve.
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