Jurisdiction(s):
United Kingdom and Ireland

UK Modern Slavery Act 2015 at ten years: updated s 54 guidance, proposed sanctions, and escalating civil, criminal and regulatory exposure in supply chains

Published on: 10 April 2025

Published by a LexisNexis Practice Compliance expert

Legal News

Article summary

Late last year, the Home Office issued a policy paper. It was triggered by a House of Lords committee review into the effect of MSA 2015. While the committee hailed MSA 2015 as pioneering, it emphasised that ‘the world has changed and best practice has moved on’. It urged government to introduce ‘proportionate sanctions’ for organisations that fail to comply with the Act’s obligations; most notably the annual requirement for companies to report on measures to identify and prevent modern slavery. The report also portrays a ‘current approach of no enforcement’ in relation to MSA 2015. Under the Act, businesses with turnover exceeding £36m must publish a yearly slavery and human trafficking statement. However, it does not set out what that statement must contain. The policy paper further notes that, although the Home Secretary can seek an injunction to enforce compliance, this has not been used because of ‘the cost to the taxpayer of seeking injunctions and the difficulties assessing compliance within the current legislative framework’. At present, we are in a position where the government recognises that laws will need...

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