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Modern slavery regulation is entering a new phase. For more than a decade, many laws focused primarily on transparency, requiring companies to publish annual statements explaining how they identified and addressed modern slavery risks in their operations and supply chains. That approach helped raise awareness at board-level and increased public accountability, but it also exposed a weakness – disclosure alone does not necessarily drive change.
Across jurisdictions, governments are now introducing more robust requirements. Increasingly, organisations are expected to not only report on their activities but also to demonstrate that they have effective due diligence systems, understand where their highest risks sit, take proportionate action, and measure the effectiveness of those actions.
For ISEP members, this shift matters because modern slavery is no longer a sustainability or corporate responsibility issue. It is becoming a governance, procurement, risk management, legal, trade and operational issue.
The direction of travel is clear – organisations are being expected to move from describing their intentions to proving their systems work.
A global shift in approach
While modern slavery legislation has developed differently around the world, there is a recognisable pattern. Early laws focused on transparency in supply chains. The UK’s Modern Slavery Act 2015 requires certain organisations to publish annual statements outlining the steps they have taken to address slavery and human trafficking in their business and supply chains. Updated UK government Home Office guidance continues to frame transparency as a tool for accountability and sustained progress.
Australia adopted a similar model through its Modern Slavery Act 2018. Since 2019, organisations have been required to publish annual statements describing modern slavery risks and actions taken to address them. Like the UK Act, it is primarily a reporting regime rather than a full mandatory due diligence law, although current reform discussions point towards stronger expectations around due diligence, enforcement and accountability.
Canada has followed a comparable path, but with more detailed statutory reporting requirements. The Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force in January 2024 and applies to certain entities and government institutions. It requires annual reporting on policies, due diligence processes, remediation, training and effectiveness. It also amended Canada’s Customs Tariff by prohibiting imports of goods that are mined, manufactured, or produced wholly or in part by forced labour or child labour.
However, the global landscape is now moving beyond reporting.
The European Union has become a major driver in this shift. The EU Corporate Sustainability Due Diligence Directive (CSDDD), which entered into force in 2024, requires in-scope organisations to identify and address adverse human rights and environmental impacts within their operations, subsidiaries and global value chains. While the EU's Omnibus Directive has simplified the legislation, the core policy direction is still important – due diligence is evolving into a legal requirement rather than just a voluntary exercise.
Alongside this, the EU Forced Labour Regulation introduces a market-access tool. From December 2027, linked to forced labour will be prohibited from being placed, made available in, or exported from the EU market. While the CSDDD focuses on company due diligence processes, the Forced Labour Regulation focuses on products and trade restrictions. Together, the two measures create both process-based and product-based accountability.
European countries have also developed national due diligence laws. France’s Duty of Vigilance Law requires large companies to establish vigilance plans to identify risks and prevent serious human rights, health, safety, and environmental impacts. Germany’s Supply Chain Due Diligence Act obliges large organisations to identify, prevent and address human rights risks, including child labour and forced labour. Switzerland has introduced targeted due diligence and transparency obligations relating to conflict minerals and child labour.
Companies in scope must adopt a child labour supply chain policy, implement traceability systems, establish a grievance mechanism, identify and mitigate child labour risks, and report publicly on compliance.
The US is taking a different but equally influential route – enforcement through customs and trade. The Uyghur Forced Labor Prevention Act has already put importers under pressure to evidence that goods are not linked to forced labour. More recently, the US Trade Representative initiated Section 301 investigations into 60 major trading partners in relation to alleged failures to impose and effectively enforce bans on goods produced with forced labour. Forced labour enforcement is now being treated not only as a human rights issue but also as a question of trade policy, market access and competitive fairness.
Elsewhere, in the Commonwealth, the picture is mixed but moving. Australia’s Modern Slavery Act 2018 remains primarily disclosure-based, but reform debates are active. The Australian anti-slavery commissioner has published recommendations to strengthen the Act, including through a mandatory due diligence obligation and a mechanism to declare high-risk matters. New Zealand has introduced a new Modern Slavery Bill. The UK continues to face calls for stronger enforcement and mandatory due diligence requirements.
Across Asia and Africa, the regulatory picture remains uneven. In Asia, the direction of travel is increasingly towards broader human rights and environmental due diligence frameworks that would capture modern slavery within wider adverse human rights impacts. Thailand is developing responsible business conduct legislation; South Korea has reintroduced a proposed mandatory human rights and environmental due diligence law; and Indonesia is moving towards a more formal business and human rights compliance framework.
In Africa, the shift is currently more policy-led than legislation-led, with a growing number of states adopting or developing National Action Plans on Business and Human Rights. Although these plans are not equivalent to mandatory due diligence laws, they signal increasing alignment with the UN Guiding Principles on Business and Human Rights (UNGPs) and may influence future legal, procurement and regulatory expectations for companies operating in or sourcing from the region. In all cases, many businesses operating in these regions are being affected indirectly through export market requirements imposed by the EU, US, Canada, the UK and Australia.
The practical implication is that organisations can no longer treat modern slavery compliance as an annual reporting exercise.
Publishing a statement may still be required, but it is no longer sufficient to point to policies, suppliers codes of conduct, or periodic audits. Regulators, investors, customers and civil society increasingly expect evidence of an effective operating system in practice.
First, governance expectations are rising. Companies need clear board and senior management oversight, defined responsibilities, escalation routes and cross-functional coordination. Modern slavery risks often sit across procurement, legal, compliance, sustainability, HR, operations and logistics. If those functions operate in silos, risks can be overlooked or managed inconsistently.
Second, supply chain oversight needs to go beyond Tier 1. Many of the most serious forced labour and child labour risks occur deeper within supply chains – often involving raw materials, subcontracting, labour providers, recruitment agencies, and informal workforces.
As a result, organisations need greater visibility beyond direct suppliers. This may involve supply chain mapping, traceability initiatives and targeted engagement with suppliers operating in higher-risk sectors or regions.
Third, companies need to adopt a risk-based due diligence approach. That means identifying where the most severe and likely risks exist such as sector, geography, product type, workforce profile and business model. Heightened risks are often associated with migrant labour, recruitment fees, seasonal workforces, informal subcontracting, downward price pressure, short lead times or weak worker representation.
Fourth, procurement practices are becoming part of the compliance conversation. A organisation cannot credibly address forced labour risk if its own purchasing practices contribute to excessive overtime, unauthorised subcontracting or wage suppression. Best practice procurement measures include prompt payments, realistic lead times, fair negotiations, supporting suppliers, and adopting a shared-responsibility approach.
Fifth, companies need credible grievance and remediation mechanisms. Regulators increasingly expect businesses to not only identify harm, but also to it. Simply terminating relationships when problems emerge may worsen outcomes for affected workers. Effective grievance and remediation systems should allow concerns to be raised safely, investigated thoroughly and resolved appropriately wherever possible.
For multinational organisations, the main challenge is navigating a growing patchwork of requirements, that differ in scope, terminology, thresholds, enforcement mechanisms and reporting requirements. A company may be subject to UK or Canadian reporting obligations, EU due diligence expectations, US customs scrutiny, contractual requirements from customers, investor expectations and sector-specific standards simultaneously.
This creates compliance complexity, but it also creates an opportunity.
Rather than building separate processes for each jurisidiction, organisations should develop a single risk-based human rights due diligence framework capable of generating evidence needed for multiple purposes. The framework should support modern slavery reporting, supplier engagement, import controls, board reporting, customer questionnaires, investor scrutiny and regulatory investigations.
The most effective approach is therefore not ‘one law, one response’. It is to build a consistent due diligence system with jurisdiction-specific outputs.
Organisations should begin by understanding where they operate, where they source products and services, where they sell into regulated markets, and which legal obligations apply.
Key actions include:
Modern slavery legislation is no longer simply about publishing an annual statement. Increasingly it is a test of whether companies understand their value chains, manage human rights risks proportionately, and can demonstrate meaningful action.
For ISEP members, this creates a clear mandate – integrate modern slavery risk into wider sustainability, governance and risk management systems now, before regulatory scrutiny, customer pressure or trade enforcement forces a more reactive response.
The global direction of travel is towards due diligence, accountability and market-access consequences. Organisations that act now will not only be better placed to comply with evolving regulations but will also build more resilient, transparent and responsible supply chains.
Dimitra Serafeimidi is a consultant and training coordinator at Ardea International
