A worker trapped in forced labour is unlikely to care whether the company at the top of the supply chain publishes an exemplary modern slavery statement. What matters is whether that company has taken meaningful steps to identify and prevent the exploitation in the first place.
Last year, after providing evidence to the Joint Committee on Human Rights' inquiry into forced labour in UK supply chains, I argued that the UK's transparency-based approach to tackling forced labour had reached its limits. While section 54 of the Modern Slavery Act 2015 requires large businesses to report on the steps they have taken to address modern slavery risks, it does not require them to take any particular action.
For more than a decade, the UK's approach to forced labour in supply chains has been built primarily on transparency. Large businesses have been required to disclose what they are doing to tackle modern slavery, but not necessarily to take any particular action. Supporters hoped that public scrutiny would drive change. Critics argued that disclosure alone was never going to be enough.
On 30 June 2026, the Government announced its most significant reforms to the Modern Slavery Act 2015 since the legislation was introduced. As part of the Immigration and Asylum Bill, it proposed substantial amendments to section 54, the provision that governs modern slavery reporting by businesses. The reforms are welcome and long overdue. They should improve consistency, accountability and enforcement. Yet they also highlight a broader question about whether transparency alone can ever be enough to prevent forced labour from occurring.
A welcome change to section 54
When the Modern Slavery Act was enacted in 2015, the UK was widely regarded as a leader in corporate transparency on modern slavery. Section 54 required large businesses operating in the UK to publish annual slavery and human trafficking statements describing the steps they had taken to address risks within their operations and supply chains.
The legislation was innovative at the time. However, experience has exposed significant weaknesses in the reporting regime. Companies have enjoyed considerable discretion over the content of their statements, enforcement has been virtually non-existent and there have been no meaningful financial consequences for non-compliance.
The proposed amendments seek to address many of these concerns. They would require businesses to report against prescribed categories, including risk assessments, due diligence processes, policies, training programmes and measures of effectiveness. The reforms would also place reporting deadlines on a statutory footing, require formal statements as to their accuracy and introduce financial penalties for failure to comply. Businesses could face fines of up to £1 million or 1% of turnover, whichever is greater. These reforms represent a significant strengthening of the existing framework and should be welcomed.
The proposed changes also reflect growing recognition that the existing framework has not delivered the level of accountability originally envisaged. Parliamentary committees, civil society organisations and anti-slavery experts have repeatedly called for stronger reporting requirements and more effective enforcement mechanisms. The Government has now taken an important step in that direction.
Transparency is not the same as prevention
Despite these improvements, the fundamental architecture of section 54 remains unchanged.
The legislation would still require companies to disclose what they are doing. It would not require them to undertake adequate human rights due diligence. Nor would it impose a legal obligation to identify, prevent, mitigate and remediate forced labour risks within their operations and supply chains.
That distinction is crucial.
Imagine two companies sourcing goods from a region where forced labour risks are well documented.
Company A invests heavily in preventing exploitation. It maps its supply chains, investigates risks, engages with suppliers, commissions independent audits, takes remedial action where problems are identified and terminates relationships with suppliers who fail to improve.
Company B takes a very different approach. It carries out limited checks, undertakes no meaningful investigation of known risks and takes few practical steps to address concerns when they arise.
Under the proposed section 54 regime, both companies may still comply with the law provided they accurately report what they have done. Company A would disclose a comprehensive due diligence programme. Company B would disclose a far less rigorous approach.
The difference between their efforts to protect workers would be substantial. The difference in their legal obligations would be far less substantial.
This example highlights the continuing limitation of a transparency-based regime. The proposed reforms make disclosure more rigorous and more enforceable. However, transparency and prevention are not the same thing. Forced labour is rarely caused by a lack of reporting. It is caused by a failure to identify and address exploitation in practice.
For workers facing coercion, debt bondage, threats or restrictions on freedom of movement, the distinction matters enormously. A detailed report may increase public awareness. It does not necessarily prevent abuse from taking place.
Why the UK still lags behind international developments
The reforms also leave the UK increasingly out of step with developments elsewhere.
Across the world, policymakers have started to recognise the limits of disclosure-based regulation. Transparency remains important, but many jurisdictions are now moving towards legal frameworks that require businesses to take proactive steps to identify and address human rights risks.
This reflects a broader shift in regulatory thinking. The focus is no longer simply on whether companies are reporting risks. Increasingly, attention is turning to whether they are taking adequate steps to prevent harm from occurring.
There are good reasons for this approach. A reporting-only regime can create an uneven playing field. Businesses that invest significant resources in due diligence and remediation may find themselves competing against organisations that undertake minimal action but nevertheless remain legally compliant. Stronger obligations can help ensure that responsible businesses are not disadvantaged for doing the right thing.
The international debate has increasingly moved from transparency towards prevention. While the Government's proposed amendments modernise section 54, they do not yet make that same transition.
The next step: a duty to prevent forced labour
The Government's proposed amendments represent genuine progress. Mandatory reporting categories, statutory deadlines and meaningful financial penalties address many of the shortcomings that have undermined section 54 since its introduction. Had these measures existed from the outset, the UK's transparency regime might well have been more effective over the past decade.
But stronger reporting requirements alone are unlikely to eradicate forced labour from UK supply chains.
If the objective is genuinely to prevent exploitation, rather than simply improve disclosure about it, Parliament will ultimately need to go further. The logical next step is legislation that requires businesses to identify, prevent, mitigate and remediate forced labour risks throughout their operations and supply chains, supported by effective enforcement mechanisms.
The Government's reforms suggest that momentum for change is growing. That should be welcomed. Yet they also underline a larger truth that has become increasingly difficult to ignore after more than a decade of transparency reporting.
The law should not merely require companies to explain what they have done about forced labour.
It should require them to take reasonable steps to prevent it and hold them accountable when they fail to do so.
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