Who needs to report
Any organisation which has a business or part of a business in the UK which provides goods and services, and has a turnover of £36 million or more, including turnover of subsidiaries. must produce an MSA statement on an annual basis.
More detail can be found in section 54 of the Act. Even if your business is not captured in this legislation, voluntary MSA reporting is encouraged, and we note that the Act is set to be expanded in future.
Updates to the Modern Slavery Act
In the Government response to the Transparency in Supply Chains consultation, published on 22 September 2020, the Home Office committed to changes to strengthen the reporting requirements under section 54 of the Act, including:
- extending the reporting requirement to public bodies with a budget of £36 million or more;
- mandating the specific reporting topics statements must cover;
- setting a shared reporting period (1 April – 31 March) with organisations having up to six months to produce their statements on activity during this period and publishing their statements by a single reporting deadline of 30 September; and
- requiring organisations to publish their statement on the new Government’s Modern Slavery Statement Registry
These changes have not yet been implemented, and will require legislative change. The Home Office has committed to engaging with organisations on when the new reporting requirements will come into effect, and will also publish new guidance to support organisations to meet the new requirements. However, in the meantime organisations may choose to align their current reporting with the future reporting requirements.
Companies can sign up to the contact database for modern slavery reporting guidance and resources (here) to receive updates on the duty to produce modern slavery statements under the Modern Slavery Act.