Checklist: UK Modern Slavery Act reporting requirements: Section 54 (UK)

Introduction

This checklist provides guidance to in-house counsel and compliance professionals in organisations in the UK on how to comply with the reporting requirements of section 54 of the UK Modern Slavery Act 2015 (MSA).

The checklist covers the following steps:

1. Check if your organisation is required to create a modern slavery statement under section 54
2. Ensure the statement includes the reporting requirements
3. Ensure the statement meets legal requirements
4. Ensure the statement is formatted correctly
5. Meet post-publication requirements

It is presented as a list of requirements that you can check off as each is addressed. At the end of the document, there are explanatory notes corresponding to each step in the checklist.

Step 1 – Check if your organisation is required to create a modern slavery statement under section 54

Step 2 – Ensure the statement includes the reporting requirements

Step 3 – Ensure your statement meets legal requirements

Step 4 – Ensure the statement is formatted correctly

Step 5 – Meet post-publication requirements

Legal framework

The checklist covers the legal requirements and guidance under:

• Modern Slavery Act 2015 (MSA)
• Supply of Goods and Services Act 1982 (SGSA)
• The Home Office Transparency in Supply Chains: A Practical Guide (2025 Updated Home Office TISC practical guide)
• Home Office guidance from the UK government on modern slavery statements (Updated Home Office guidance)
• The Beyond Compliance: Effective Reporting Under the Modern Slavery Act guide by CORE (the CORE guidance)

Notes on specific requirements

Step 1 – Check if your organisation is required to create a modern slavery statement under section 54

Step 1 of the checklist is a sequence of questions to help you decide if a modern slavery statement is required. Answer every question in order.

1.1 Is your business a commercial organisation that is a body corporate or a partnership, wherever incorporated or formed?

The MSA applies to multinational organisations and group companies. Section 54 covers both UK and non-UK entities.

‘commercial organisation’ in this context means (section 54(12) MSA):

• corporate bodies that carry on business or part of a business in the UK; and
• partnerships that carry on a business or a section of the organisation in the UK. The types of partnerships covered are: partnerships within the Partnership Act 1890, a limited partnership registered under the Limited Partnerships Act 1907 or a firm, or an entity of a similar character, formed under the law of a country outside the UK.

‘business’ includes a trade or profession (section 54(12) MSA).

Educational enterprises such as universities do not fall under this requirement; however, charities could be required to make a statement and be seen as a business. See note 1.5.

1.2 Does your organisation carry on a business, or part of a business, in the UK?

If your organisation has a demonstrable business presence in the UK (carries on business) and meets other criteria, you should publish an annual statement.

1.2.1 Non-UK businesses and multinational organisations

The 2025 Updated Home Office TISC practical guide states that if your foreign organisation has a demonstrable business presence in the UK and meets the other criteria in section 54, it should publish an annual statement.

To assess if your organisation has a demonstrable business presence in the UK, consider whether any of the following factors apply to it:

• registration at UK Companies House;
• UK office;
• provision of services or support functions in the UK;
• receipt of income in the UK; or
• another visible UK business presence, such as a website and advertisements.

One or more factors need to apply to show a business presence in the UK (note, this is a non-exhaustive list and other factors will apply depending on the organisation).

1.3 Does your organisation supply goods or services?

One requirement to determine if a statement should be published is whether your organisation supplies either goods or services.

Holding companies may not meet the criteria for publishing a statement because they do not trade goods or services themselves. However, any organisations within a holding company’s corporate group that do meet the criteria must publish a statement or be covered by a group statement.

1.4 Has your organisation got an annual turnover of £36 million or more?

1.4.1 Calculating turnover

Turnover is discussed in the 2025 Updated Home Office TISC practical guide.

‘Total turnover’ means the turnover of your organisation including the turnover of any of your subsidiary undertakings (including those operating wholly outside the UK).

‘Turnover’ means ‘the amount derived from the provision of goods and services falling within the ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of – trade discounts, value added tax, and any other taxes based on the amounts so derived.’

1.4.2 Publication date

A statement is required if the £36 million threshold requirement is met for financial years ending on or after 31 March 2016.

Your organisation is legally required to publish a statement for each financial year. You should publish your statement as soon as possible after your financial year ends. This is usually, at most, within six months of your organisation’s financial year end.

1.4.3 Public sector and smaller organisations

The MSA has not yet been extended to public sector organisations, but these organisations can still choose to voluntarily produce a statement. In 2020, during a consultation process seeking views on proposed changes to transparency in supply chain reporting, it was recognised that the public sector, due to its spending powers and influence, needed to be brought into the scope of the MSA.

The UK Government has in the past published a Government Modern Slavery Statement (last published in 2023 for the year ending 31 March 2002), which set out the steps it had and would be taking to reduce modern slavery from its supply chains and use its annual spending more responsibly. Other parts of the UK public sector have continued to publish statements, such as the UK Parliament’s Modern Slavery Statement for 2024-2025.

Section 54 of the MSA does not apply to smaller organisations that do not meet the £36 million turnover threshold, but they may choose to make a statement voluntarily for other benefits such as public reputation.

The UK Government’s updated guidance on publishing an annual modern slavery statement suggests that smaller organisations may find it helpful to make a voluntary statement in some specific circumstances. For example:

• when responding to supply chain due diligence queries, a statement or policy setting out your approach to tackling modern slavery is a convenient and quick way to respond; and
• when bidding for contracts against organisations that have a modern slavery statement.

Even if the MSA does not apply, organisations are urged to be honest and transparent about recruitment practices, policies and procedures that relate to modern slavery. You are also encouraged to take steps that are consistent and in proportion to your sector and size (page 63, 2025 Updated Home Office TISC practical guide).

1.4.4 Investment trusts

If your organisation is an investment trust, you should publish an annual statement if it meets the turnover criteria. The investment income from dividends and shares does not need to be included in the calculation, but turnover derived from goods and services (eg, fund management services) should be taken into consideration. See the UK government’s 2025 Updated Home Office TISC practical guide.

If your organisation is a private investment trust, the portfolio organisation is not considered part of the supply chain since the relationship between a trust and a portfolio organisation is not based on the supply of goods or services. Private investment trusts are therefore (generally) not required to make a statement under section 54, although they are still recommended to do so.

1.5 Is your organisation a charity?

If your organisation is a charity, consider whether it meets the turnover criteria. Any income received from business activities (such as the provision of goods and services for a fee) should be taken into consideration in making this assessment.

If the contributor receives no service or benefit, then donations, legacies and grants are not considered to be acquired from business activities and therefore do not need to be included when calculating turnover.

Grant income could be seen to be obtained from business activities. Charities should consider whether the grant giver will obtain any benefit in return for the grant, or whether there are any specific conditions around the use of the grant when assessing whether to include this income in its turnover assessment.

1.6 Is your organisation one which is in, or entering, administration?

The UK guidance indicates that an organisation that is in, or entering administration, must still consider whether it meets the requirements for the relevant financial year.

An organisation that is no longer trading is not usually required to publish an annual statement. If your organisation decides to continue trading while in administration, and it meets the section 54 requirements, it must publish a statement.

1.7 Does your organisation fall under a franchise model?

The franchisor must prepare a statement if its total turnover is £36 million (and it satisfies the other section 54 requirements). Only the franchisor’s turnover will be counted in the assessment, and not that of a franchisee using the franchisor’s trademark.

Where the franchisee’s total turnover is £36 million, and it satisfies the other section 54 requirements, it must produce its own slavery and human trafficking statement. (See page 61, 2025 Updated Home Office TISC practical guide).

1.8 Does your organisation encompass a parent–subsidiary structure?

Consider each parent and subsidiary organisation in any group structure your organisation is part of, when assessing whether it fulfils the section 54 requirements (ie, as a body corporate or partnership carrying on business or part of a business in the UK that meets the requirement of an annual total turnover of £36 million). This will determine whether your individual organisation must publish a statement.

A parent organisation that meets all of the section 54 requirements must publish its own statement and include in its statement the steps taken by itself and its subsidiaries. This applies if the subsidiaries’ activities are part of the parent’s supply chain or organisation and regardless of whether the subsidiaries meet all the section 54 requirements. Subsidiaries must also create a statement for themselves where they meet the requirements, see 1.8.1, unless their parent company publishes a statement on their behalf.

1.8.1 Does your subsidiary organisation meet the section 54 requirements in its own right?

If your organisation is a subsidiary organisation that meets the section 54 requirements in its own right, it must produce a statement of its own.

If both the parent and its subsidiaries must make a statement, the parent may produce one statement that can be used by its subsidiaries. The statement will need to mention the steps taken in the relevant financial year by the parent and each subsidiary using the statement (pages 63-64, 2025 Updated Home Office TISC practical guide).

The 2025 Updated Home Office TISC practical guide suggests that if a group chooses to publish a single statement, it must cover the steps taken to prevent modern slavery in all the organisations within that group that meet the section 54 criteria, and their supply chains. The statement should clearly name the parent and subsidiary organisations to which it applies, and be published on their UK websites.

1.8.2 Is your subsidiary non-UK but part of the UK parent organisation’s supply chain or own business?

A non-UK subsidiary that does not do business in the UK will not have to make a statement. However, it is good practice for a UK parent company to cover a non-UK subsidiary in its statement. This is particularly the case if the non-UK subsidiary is in a high-risk location, which is often the case for supply chains (pages 61-62, 2025 Updated Home Office TISC practical guide).

If your organisation is a non-UK subsidiary and part of the UK parent company’s business or supply chain, the parent company’s statement should mention actions undertaken by your organisation to prevent modern slavery (page 61, 2025 Updated Home Office TISC practical guide). See also How-to-guide: How to create a supplier code of conduct (UK) for related information on maintaining supply chain transparency.

1.8.3 Is your organisation’s parent a non-UK parent?

If your UK organisation has a non-UK parent carrying on a business or part of a business in the UK, while also meeting the other section 54 requirements, the non-UK parent must produce a statement (decided on ‘a common sense approach’) as set out in the 2025 Updated Home Office TISC practical guide.

If your UK organisation has a non-UK parent and is required to make a statement, your organisation may do so independently of its parent (page 61, 2025 Updated Home Office TISC practical guide).

The 2025 Updated Home Office TISC practical guide states that overseas organisations trading in the UK or UK organisations trading overseas must publish a statement if they have a demonstrable business presence in the UK and meet the other criteria. There are several considerations to determine if a parent company has a demonstrable business presence in the UK. Refer to 1.2 to see what these include.

Step 2 – Ensure the statement includes the reporting requirements

Step 2 sets out what to include in your statement.

The 2025 Updated Home Office TISC practical guide says the key purpose of section 54 of the MSA is ‘to prevent and mitigate modern slavery in organisations and their supply chains.’ By increasing transparency, organisations are ‘ensuring the public consumers, employees, trade unions and investors know what steps an organisation is taking to tackle modern slavery’ (page 8, 2025 Updated Home Office TISC practical guide). By including the 6 reporting requirements, organisations line themselves up with the OECD due diligence process and UNGPs. (page 11, 2025 Updated Home Office TISC practical guide). Therefore, you are encouraged to take account of the items set out in Step 2 of this checklist and the points mentioned in section 54(5), MSA.

2.1 Information about the organisation’s structure, business and its supply chains

It is recommended to include information about your organisation’s structure, its business and its supply chains in your modern slavery and human trafficking statement. These are referenced in the 2025 Updated Home Office TISC practical guide and reiterated in the CORE guidance.

This information could include:

• the size of your organisation, the countries that your organisation operates in and the different trading entities;
• the location of your organisation’s operations and the countries that your organisation sources from;
• a high-level profile of your organisation’s direct and indirect suppliers;
• mapping of structures and relationships with suppliers and contractors, including a high-level profile of indirect suppliers (eg, subcontractors) down to the lowest tier;
• an overview of your organisation’s labour supply chain, including information about  employees that have seasonal contracts;
• details of roles and responsibilities, including senior-level oversight and management of modern slavery risk; and
• a list of stakeholders engaged  to map the supply chain. 
   

2.2 Policies relevant to addressing slavery and human trafficking

Your organisation should include in its statement information on any human trafficking and modern slavery policies it has in place (section 54(5), MSA).

It is useful to refer to and provide links to policies addressing recruitment, migrant labour, whistle-blowing, child labour, grievances and other relevant policies that address business and supply chain relationships. It may also be helpful to include policies relating to your code of conduct, details of employee training and awareness of modern slavery, and the remedies and compensation mechanisms for labour rights abuses.

Policies should be established and clearly communicated so that anti-slavery activity within your organisation and its supply chains becomes standard practice.

2.2.1 Modern slavery policy

It is up to you how detailed you want to make your policy on modern slavery. The Home Office suggests organisations consider the following questions.

• What minimum labour standards are expected of your organisation, its subsidiaries, and suppliers, and how do these align to industry standards?
• Does your organisation have a responsible purchasing policy in place, oversight of how your purchasing practices might be contributing to the risk of modern slavery, and a strategy in place for identifying, preventing and mitigating risk in relation to purchasing practices?
• Who in your organisation is responsible for:
  • ensuring efforts are made to investigate and remediate the risk of modern slavery in the organisation and/or supply chains; and
  • ensuring that basic labour standards are met, and how such leaders are financially incentivised and resourced to do so?
• What is your organisation’s recruitment policy across your organisations, subsidiaries and suppliers?
• What is your organisation’s policy on freedom of association, collective bargaining and union busting in your organisation, subsidiaries and suppliers?
• What is your organisation’s policy to support whistleblowing? What procedures are in place to assist reporting, including reporting by workers through helplines?
• How does your organisation support access to remedy for those who experience modern slavery in your organisation and supply chains? What measures are taken to protect them from further victimisation or vulnerability?
• What support or guidance is available to business operations or suppliers with an obligation to provide or contribute to remedy in situations where modern slavery is found?
• How does your organisation factor legal and fair full labour costs into production and sourcing budgets to avoid the need for seemingly cheaper forced or bonded labour in operations or the supply chain?
• What is your organisation’s policy where a supplier is found to have been involved in modern slavery? Does your organisation have a process in place for responsible exit from contracts when all measures to address instances of modern slavery have been exhausted?
• When entering a contract with a new supplier or renewing contracts with existing suppliers what checks, assurances and investigations will your organisation conduct or accept?
• What support or guidance is available to your organisation’s operations or suppliers who are attempting to remediate situations of slavery or forced labour?
• What due diligence will your organisation commit to conducting regarding its supply chains? (See section 2.3 below on due diligence).

2.3 Clearly stated due diligence processes for human trafficking and slavery in the organisation and its supply chains

In the statement, you should refer to any due diligence processes for modern slavery and human trafficking within the organisation and supply chains (section 54(5) MSA).

Human rights due diligence is a key concept in the UN Guiding Principles on Business and Human Rights (UNGPs). The UNGPs specify that due diligence processes should include:

• an assessment of actual and potential human rights impacts;
• integrating and acting upon the findings;
• tracking responses; and
• communicating how impacts are addressed.

The Home Office practical guide relates to corporate good governance. It forms part of a wider framework around ethical trade, corporate social responsibility (CSR) and human rights. Addressing modern slavery should be part of the overall due diligence processes into these areas.

Effective due diligence also requires consultation with stakeholders that are or could be affected by your organisation’s operations and supply chains, particularly vulnerable groups, such as children. Due diligence procedures should be proportionate to the identified modern slavery risk and its severity. They should also reflect the level of influence your organisation may have and be informed by any broader risk assessments that have been conducted.

Procedures may vary depending on the relationships within your organisation and supply chains. For instance, your organisation may have good knowledge about its first-tier suppliers, and so its stakeholders may expect to see a high level of engagement with them. However, you should also engage your lower-tier suppliers where possible.

It is expected that your organisation will ensure the integrity of any investigations during due diligence. It is advisable to investigate working conditions with support from expert, independent third parties and civil society stakeholders, and speak to workers directly about your organisation’s working conditions.

The 2025 Updated Home Office TISC practical guide lays out the following information an organisation could include in their statement:

• prevention and mitigation measures undertaken to cease and prevent modern slavery;
• supplier and worker engagement;
• human rights due diligence approach;
• grievance mechanisms;
• remediation policies and processes;
• incidents of modern slavery;
• business model;
• stakeholder engagement; and
• continuous improvement.

(See pages 38-40, 2025 Updated Home Office TISC practical guide).

2.4 Identified areas at risk of human trafficking and slavery in the organisation and supply chains, and the steps being taken to manage them

Identify the parts of your organisation and supply chains where there is a risk of modern slavery and human trafficking, and the actions your organisation has taken to evaluate and handle the possibility of modern slavery.

Under this section, you should consider including information on how your organisation identifies and assesses modern slavery risks and the sources it uses. It should disclose its most salient modern slavery risks to workers in the organisation and supply chains, and evidence any engagement with internal and external stakeholders to identify, assess and prioritise risks.

Information on social auditing and similar risk management plans within your organisation’s policy statement can also be added here. You should disclose actions planned and taken on how to manage modern slavery risks, monitor and evaluate the measures that currently exist and report risks of modern slavery. 

2.5 Information on the effectiveness of measures to ensure that human trafficking and slavery are not taking place

It is important to set out the effectiveness of steps taken to ensure that slavery and human trafficking is not taking place within your organisation or its supply chains. The 2025 Updated Home Office TISC practical guide suggests that steps taken are measured against key performance indicators (KPIs). This will allow consumers and potential business partners to determine if your organisation has identified an issue and, if so, see how it responded. (2025 Updated Home Office TISC practical guide).

Your organisation may choose to disclose identified cases of modern slavery and subsequent action plans, alongside details of its grievance mechanism. Consider publicising your key performance indicators alongside details about your organisation’s related decisions. 

2.6 Information on the training that is available to staff on human trafficking

The Modern Slavery Statement may include details about staff training on modern slavery and human trafficking (section 54(5) MSA).

According to the 2025 Updated Home Office TISC practical guide, investment in training and development is worthwhile given the benefits it provides to your organisation and its employees. The expense can be minimised if relevant training is part of wider training on similar issues.

Include all details of training given to raise awareness of modern slavery and the potential signs and risks of forced or unfair labour within the organisation and its supply chains. Consider including information about the content, objectives, numbers, and outcomes of training delivered to:

• the whole organisation;
• the organisation’s frontline staff;
• those most at risk of exploitation;
• human resource staff;
• executive-level staff;
• procurement staff;
• the organisation’s suppliers; and
• the wider community.

Consider also including information about:

• frequency of training;
• detail on how training has been tailored to different; roles/responsibilities
• attendees (including roles and responsibilities);
• how training is reviewed and updated; and
• how training is evaluated (eg, via feedback from participants).

See CORE’s recommended content for a modern slavery statement.

Step 3 – Ensure your statement meets legal requirements

3.1 State whether any steps were taken to stop human trafficking and modern slavery in business operations and supply chains, or state that no such steps were taken

The statement must cover the actions your organisation has taken during the financial year to ensure that slavery and human trafficking are not occurring in any section of your organisation, or you must state that your organisation has not taken any steps (section 54(4) MSA). If your organisation states that it has not taken any steps, it could provide the reasons why not. 

3.2 Ensure that the statement is approved by the board of directors or equivalent bodies

The board of directors is responsible for authorising the statement, so at least one board member should supervise the process of reviewing it. Although CSR or sustainability teams might be involved in the procedure, it is not suitable for them to be the sole or main party involved in the reviewing process. The review should look at the parts of your organisation where the risks of modern slavery are high, such as purchasing, procurement and human resources. You are recommended to set out the procedure your organisation takes to review the statement. See the CORE guidance.

3.3 Ensure that the statement is signed by a director

Your organisation must authorise the modern slavery and human trafficking statement. If your organisation has one, the board of directors must approve the statement and it must be signed by a suitable director. Statements from limited liability partnerships must be confirmed by the members of the partnership, and signed by a designated member. Limited partnerships registered under the Limited Partnerships Act 1907 must have it signed by a general partner (section 54(6) MSA).

3.4 Publish the statement on your organisation’s website in a prominent position

If your organisation has a website, the statement should be published on it clearly. Provide a link on the homepage, or in an obvious space (section 54(7) MSA).

If your organisation has more than one website, the 2025 Updated Home Office TISC practical guide recommends publishing the statement on the most appropriate website relating to the organisation’s business in the UK. Where there are multiple relevant websites under your organisation, a copy of or link to the statement should be available on each (page 67, 2025 Updated Home Office TISC practical guide).

3.5 If your organisation does not have a website, offer a copy of the statement to those who make a written request

If your organisation does not have a website, you must give a copy of the slavery and human trafficking statement to anyone who makes a written request for it within 30 days of such a request (section 54(8) MSA).

Step 4 – Ensure the statement is formatted correctly

4.1 Information contained in the statement should be accurate, comprehensive and relevant

A reader of the statement should be able to understand the nature of your organisation and its subsidiaries. Ensure all your organisation’s subsidiaries are covered by your statement, even if the subsidiary does not provide products or services for the UK.

This is an opportunity for your organisation to show that it has developed a well thought through response to modern slavery. See page 20 of the CORE guidance.

4.2 Where relevant, provide the statement in other languages

Home Office guidance suggests the statement should be in English but may additionally be offered in other languages that are suited to your supply chains. It highlights that identifying actions by specific country will improve the understanding of the context in which the steps should be taken (page 66, 2025 Updated Home Office TISC practical guide).

4.3 The statement must be succinct but mention all relevant details and should link to relevant publications, documents or policies

The Home Office recommends the statement be short but include all the necessary details and links to appropriate publications, files or procedures to ensure they are easily accessible to everyone (page 66, 2025 Updated Home Office TISC practical guide).

4.4 Use of simple language is encouraged

The Home Office suggests the use of simple language to ensure the statement is easy to understand. The less space for inference, the better your statement is at doing its task.

4.5 The layout of the statement is not prescriptive although many companies follow the section 54 reporting criteria

The layout of the statement is not prescriptive although many companies follow the reporting criteria. Section 54 suggests what can be included; however, this list is not a requirement. The suggestions are there to help your organisation.

Step 5 – Meet post-publication requirements

Step 5 is a list of requirements for after you have published the statement.

5.1 Continue to produce a statement in future financial years, even if your turnover has fallen below the £36 million threshold

The Home Office guidance firmly recommends that organisations producing a statement should continue to do so in the future years, even if turnover has reduced to below the £36 million threshold. Producing a consistent annual statement demonstrates your organisation’s ability to improve on previous statements and your commitment to transparency (page 68, 2025 Updated Home Office TISC practical guide).

5.2 Publish the statement on government-run modern slavery statement registry

The government encourages you to publish your statements on the government-run modern slavery statement registry, launched by the Home Office on 23 February 2021. (This is one of the proposed changes to section 54).

Modern slavery statements can be added by any organisation that has created one, or has previously published an annual modern slavery statement. The Home Office creates a summary statement and publishes it on the modern slavery statement registry with a link to the full statement on your organisation’s website.

5.3 Keep previous statements available online

The Home Office guidance advises that you keep previous statements available online even after new versions are published. This enables the public to compare statements over the years and monitor your organisation’s progress.

5.4 Publish the statement after the end of the financial year or within six months of the financial year end

The Home Office guidance suggests that your organisation should publish its statement after its financial year end. Your organisation could delay the publication to publish the statement alongside other annual reports. The guidance provides that at most the statement should be published within six months of the financial year end.

This practical resource was produced in partnership with Ardea International.

Additional resources

Modern Slavery Act 2015 (Commencement No. 3 and Transitional Provision) Regulations 2015 (SI 2015/1816))
Modern Slavery (Amendment) Bill
Home Office, Transparency in Supply Chains (TISC) Statutory Guidance
Ethical Trading Initiative, Modern slavery statements: evaluation framework 

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Understanding the legal framework for human rights and the importance of human rights due diligence

Checklists:

Modern slavery in supply chains (USA)
Conducting environmental, social and governance (ESG) due diligence in supply chains
Human rights due diligence in supply chains

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