Modern slavery statements

A company or partnership that supplies goods or services, carries on business in the UK and has total turnover of at least £36 million must publish a slavery and human trafficking statement for each financial year under section 54 of the Modern Slavery Act 2015. The statement must be approved and signed at the right level, posted on the organisation’s website with a prominent homepage link, and can legally say the organisation has taken no steps, although that is rarely wise.

Which businesses must publish a statement?

Section 54(1) and (2) apply to a “commercial organisation” that supplies goods or services and has total turnover of not less than the amount set by regulations. Regulation 2 of the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, SI 2015/1833, sets that amount at £36 million. All the tests must be met:

• Type of body. Section 54(12) covers a body corporate, wherever incorporated, and a partnership, wherever formed, including a general partnership, a limited partnership and an overseas firm. LLPs are bodies corporate. Sole traders are outside the section.
• Business in the UK. It must carry on a business, or part of a business, in any part of the UK. “Business” includes a trade or profession.
• Supplies goods or services.
• Turnover of £36 million or more.

The Home Office statutory guidance, Transparency in supply chains: a practical guide (updated March 2025), expects a common sense approach to “carrying on a business”. An overseas company without a demonstrable UK business presence is not caught, and having a UK subsidiary does not by itself mean the overseas parent carries on business in the UK.

How is the £36 million turnover worked out?

Regulation 3 defines total turnover as the turnover of the organisation plus the turnover of any of its subsidiary undertakings. Turnover means amounts from goods and services within the ordinary activities, after deducting trade discounts, VAT and other taxes based on those amounts. The guidance confirms that subsidiaries count wherever they are based, including those operating wholly outside the UK.

That makes the test wider than many expect. A UK holding company with £5 million of its own turnover and overseas subsidiaries turning over £40 million has total turnover of £45 million and is in scope. The threshold is unrelated to the Companies Act company size thresholds, so a medium sized group for accounts purposes can still be caught.

The guidance gives sector points:

• Charities include income from business activities, such as goods and services supplied for a fee, but generally exclude donations, legacies and grants where the giver receives nothing in return.
• Investment trusts exclude dividend and share investment income but include income from goods and services.
• Franchises. Only the franchisor’s own turnover counts towards its threshold; a franchisee over £36 million reports in its own right.
• Administration. An organisation still trading in administration and meeting the tests must publish; one that has stopped trading generally need not.

What must the statement say?

Section 54(4) defines the statement as either a statement of the steps the organisation took during the financial year to ensure slavery and human trafficking is not taking place in any of its supply chains and in any part of its own business, or a statement that it has taken no such steps. That is the only compulsory content.

Section 54(5) lists what the statement may include:

1. the organisation’s structure, business and supply chains;
2. its policies on slavery and human trafficking;
3. its due diligence processes in its business and supply chains;
4. the parts of its business and supply chains where there is a risk, and the steps taken to assess and manage that risk;
5. its effectiveness, measured against performance indicators it considers appropriate;
6. the training available to its staff.

The 2025 guidance builds its recommendations around these six areas, with “good” and “best” practice for each, and asks organisations to show year on year progress. It also says that organisations which find no risks are unlikely to have looked hard enough, and that a “no steps” statement may damage reputation even though it is lawful. The guidance recommends plain English and allows links to fuller policies.

Who must approve and sign it?

Section 54(6) sets the approval and signing rules by type of organisation:

Organisation	Approved by	Signed by
Company or other body corporate (not an LLP)	The board of directors or equivalent management body	A director or equivalent
Limited liability partnership	The members	A designated member
Limited partnership under the Limited Partnerships Act 1907	No separate approval requirement	A general partner
Any other partnership	No separate approval requirement	A partner

The guidance describes it as best practice for the signing director to sit on the board that approved it and for the statement to give the date of approval. In practice the approval should be minuted at a properly convened meeting; see board meetings and board minutes. A statement signed by a compliance officer or general counsel who is not a director does not meet section 54(6). For LLPs, the members’ approval and the designated member’s signature are both needed; see LLPs.

Where and when must it be published?

Section 54(7) requires an organisation with a website to publish the statement on it and to put a link in a prominent place on the homepage. The guidance says a prominent place may be a link directly visible on the homepage or part of an obvious drop down menu, clearly labelled. An organisation without a website must give a copy to anyone who asks in writing within 30 days of the request, under section 54(8).

The Act sets no filing deadline, but the guidance says statements should be published as soon as possible after the financial year end and at most within six months. It encourages keeping earlier statements online and uploading each statement to the government’s modern slavery statement registry. The registry is voluntary.

How do groups handle statements?

Each parent and subsidiary that meets all the tests must publish a statement, but the guidance allows one group statement covering several entities if it names each entity covered, is approved and signed for each, and is published on the UK website of each. A parent must include steps relating to a subsidiary that is outside the tests if, on the facts, that subsidiary forms part of the parent’s business or supply chain.

Illustration only. A UK parent has £10 million of its own turnover, a UK subsidiary with £30 million and an overseas subsidiary with £20 million that sells only abroad. The parent’s total turnover is £60 million, so it must publish. The UK subsidiary is below £36 million and has no subsidiaries, so it has no duty of its own, but if it is part of the parent’s business its activities belong in the parent’s statement. The overseas subsidiary does not carry on business in the UK, so it has no duty, but the guidance strongly recommends covering it.

What happens if a business does not comply?

Section 54(11) lets the Secretary of State bring civil proceedings for an injunction in the High Court, or in Scotland an action for specific performance of a statutory duty. The guidance notes that breaching such an order is contempt of court, punishable with an unlimited fine. There is no fixed penalty for a missing statement, which is why the guidance leans heavily on reputational risk: customers, investors and campaign groups review statements, and larger customers often require suppliers to evidence their approach in tender questionnaires.

The guidance also recommends continuing to publish even if turnover falls below £36 million, because a sudden stop looks like a step backwards.

What mistakes come up most often?

• Testing the threshold on the UK company’s own turnover and ignoring overseas subsidiaries.
• Republishing last year’s text without updating the steps for the year just ended.
• Board approval not minuted, or the statement signed by someone who is not a director, designated member or partner.
• Putting the statement in a footer policy page with no prominent homepage link.
• A group statement that does not name every entity it covers, or is not published on each entity’s UK website.
• Treating the registry upload as a substitute for website publication.

Organisations in scope are usually large enough for other reporting duties too, including gender pay gap reporting where an entity has 250 or more employees.

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Related Accountapedia entries

• Payment practices reporting
• The failure to prevent fraud offence
• How to incorporate an LLP
• Partnership, LLP or limited company
• Duties of LLP members

Sources

• legislation.gov.uk: Act 2015 c. 30, section 54
• legislation.gov.uk: SI 2015/1833
• GOV.UK: Transparency in supply chains a practical guide
• GOV.UK: Transparency in supply chains a practical guide accessible

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.