UK Government Issues Updated Modern Slavery Act Transparency Guidance: Key Takeaways for Businesses

On 25 March 2025, the UK Home Office published its updated Transparency in Supply Chains (TISC): Statutory Guidance (the Guidance), which provides new and detailed recommendations to help organisations comply with Section 54 of the Modern Slavery Act 2015 (MSA). The Guidance includes clearer expectations and practical tips designed to encourage more meaningful disclosure and drive better practices across global supply chains.

While the MSA’s core transparency requirements remain the same, the Guidance places renewed emphasis on detailed reporting, alignment with international frameworks, and continuous improvement. Organisations in scope — and those choosing to report voluntarily — should take note of the key updates described below.

Expanded Practical Detail on Six Reporting Areas

Under Section 54, organisations must publish a Modern Slavery Statement each year, describing the steps they have taken to prevent modern slavery in their operations and supply chains. The Guidance structures its recommendations around the MSA’s six “reporting areas”:

1. Organisational Structure and Supply Chains (s.54(5)(a))
2. Policies (s.54(5)(b))
3. Due Diligence (s.54(5)(c))
4. Assessing and Managing Risk (s.54(5)(d))
5. Monitoring and Evaluation (s.54(5)(e))
6. Training (s.54(5)(f))

For each area, the Guidance sets out Level 1 (basic or foundational) and Level 2 (enhanced or more comprehensive) disclosure suggestions. New reporters, or those still maturing their approach, should focus on achieving Level 1 benchmarks. More seasoned reporters are encouraged to move towards Level 2, demonstrating continuous improvement and deeper engagement year on year. Importantly, the Guidance underscores that not identifying any risks or incidents of modern slavery may reflect insufficient due diligence rather than a lack of exposure. Transparency on identified risks and challenges — along with remediation efforts — is strongly encouraged.

Below are selected highlights from each of the six reporting areas, based on the Guidance:

1. Organisational Structure and Supply Chains

Companies should:

• provide an overview of their business structure, including size, geographic reach, and product/service lines;
• map out (at least at a high level) where their supply chains operate and how goods or services are sourced; and
• disclose what they do not know (for instance, mapping below tier 1), and outline steps planned to improve visibility.

2. Policies

Businesses should:

• summarise existing policies relevant to modern slavery, such as supplier codes of conduct, whistleblowing, and ethical recruitment; and
• explain how these policies are implemented and overseen by senior management, referencing international standards (e.g., International Labor Organization Conventions).

3. Due Diligence

Companies should:

• outline specific steps to prevent, detect, and remediate modern slavery in their operations and supply chains, including responsible recruitment practices; and demonstrate how they engage workers and suppliers, use audits or worker voice mechanisms, and respond to any identified incidents (e.g., remedy and compensation).

4. Assessing and Managing Risk

Organisations should:

• describe their risk assessment process, including any research tools, audits, or stakeholder engagement (e.g., suppliers, NGOs, or unions); and
• prioritise the most salient risks, detailing their likelihood, severity for workers, and any mitigating actions taken.

5. Monitoring and Evaluation

Companies are encouraged to:

• set measurable key performance indicators (KPIs) and track how well they address modern slavery risks; and
• disclose lessons learned, success stories, and next steps for improving systems and processes.

6. Training

The Guidance recommends:

• providing targeted training for different staff roles (frontline, HR, procurement, leadership) and, where feasible, extending training to key suppliers; and
• stating how training content is reviewed, updated, and measured for effectiveness.

The Guidance clarifies that legal compliance under the MSA does not hinge on the narrative quality of the statement; rather, a compliant statement will describe all steps taken (or acknowledge if no steps were taken). However, the Home Office strongly encourages robust disclosure to help drive better practices.

The Guidance aligns with frameworks such as the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct. It also anticipates emerging EU sustainability due diligence requirements, urging companies to integrate modern slavery considerations into broader ESG and human rights programmes, rather than treating the Modern Slavery Statement as an isolated exercise. Businesses subject to multiple ESG or non-financial reporting regimes are advised to adopt a unified approach to risk mapping, due diligence, and remediation, thus streamlining efforts and meeting diverse stakeholder expectations on human rights.

Operational Matters

The Guidance also provides practical clarifications on the “what, who, how, and when” of compliance, covering the following questions:

• What must companies do to ensure compliance? Organisations in scope must produce an annual Modern Slavery Statement covering the actions taken to prevent modern slavery in their operations and supply chains.
• Who must comply? Companies with a total turnover of £36 million or more that carry on any part of a business in the UK are caught by the MSA. Failure to publish (or publishing a non-compliant statement) may lead to an injunction or other penalties. Statements must be approved by the board (or equivalent) and signed by a director or designated partner.
• How should companies publish their statements? The statement should be posted in a prominent place on the organisation’s website (e.g., via a homepage link). Businesses are encouraged to upload their statements to the government’s Modern Slavery Statement Registry for greater transparency.
• When should companies publish their statements? Statements must be published annually, ideally within six months of the financial year-end. Keeping previous statements online allows stakeholders to track year-on-year progress.

Next Steps

In light of the Guidance, organisations should consider three priority actions:

1. Conduct (or refresh) a modern slavery risk assessment: Map supply chains and identify risk hotspots using the latest guidance, engaging both internal teams and external stakeholders (e.g., NGOs, unions, peers).
2. Enhance policies, procedures, and training: Integrate modern slavery considerations into existing policies, procurement processes, and staff training, ensuring clear accountability at board level.
3. Set measurable KPIs and track year-on-year improvements: Transition from “tick-box” reporting to outcome-focused metrics, demonstrating continuous improvement and preparedness for broader human rights due diligence mandates.

Latham & Watkins will continue to monitor developments related to the MSA and transparency requirements and will provide updates as they emerge.