Introduced into the House of Commons on 30 June 2026, the Immigration and Asylum Bill 2026 (the Bill) looks set to significantly overhaul the UK's corporate modern slavery reporting regime.

Published: 4 September 2026
Authors: Michelle Craven-Faulkner

The current reporting framework under the Modern Slavery Act 2015

The existing corporate modern slavery reporting regime is set out in the Modern Slavery Act 2015 (the MSA) and requires commercial organisations within its scope to publish an annual slavery and human trafficking statement.  Pursuant to section 54 of the MSA, the statement must describe the steps the organisation has taken to ensure that slavery and human trafficking are not taking place within its supply chains, or any part of its business.  Alternatively, an organisation may publish a statement confirming that it has taken no such steps.

The MSA has long been criticised for imposing relatively limited reporting obligations on commercial organisations, and for lacking meaningful sanctions.  The Bill would introduce the most significant changes to the UK’s corporate modern slavery framework since the enactment of the MSA over a decade ago.

Mandatory reporting under the Immigration and Asylum Bill 2026

Whilst the MSA identifies a number of topics that organisations may choose to address in their statements, it does not mandate the inclusion of particular information.  Organisations are therefore free to determine the content of their statement, with brevity often the preferred approach.

The Immigration and Asylum Bill would significantly overhaul this position by introducing mandatory reporting requirements relating to the content of slavery and human trafficking statements.  Under the draft proposals, organisations would be required to report on:

• their structure, operations and supply chains
• steps taken to identify, assess, and mitigate the risk of slavery and human trafficking in their business and supply chains, and where no such steps have been taken, the reasons for this
• any policies relating to slavery and human trafficking and, where no such policies are in place, the reasons for this
• any training made available to staff, and, where no such training has been provided, reasons as to why
• due diligence which has been conducted and implemented in relation to modern slavery risks
• any measures taken to assess the organisation’s effectiveness in ensuring that slavery and human trafficking is not taking place in its business and supply chains.

Financial penalties

Financial penalties under the updated regime will be determined under secondary legislation but would be capped at the higher of: (a) 1% of total turnover (for commercial organisations) or total budget (for public authorities), or (b) GBP 1 million. The updated regime would also extend to public authorities that meet certain financial thresholds (which will also be determined by way of secondary legislation).

Increased governance and accountability

In addition, organisations should prepare for:

• a longstop statement publication deadline of six months after the end of their financial year
• increased visibility at board level, with statements requiring governing body approval, as well as a personal declaration from the signatory that the statement is “accurate to the best of their knowledge and belief”.

Preparing for the proposed reforms

For organisations with established supplier due diligence, internal governance and training programmes, the proposed reforms may not require a radical overhaul of their existing processes.  However, organisations that have thus far adopted a minimum-compliance approach to their reporting obligations should start to prepare now.  Whilst the Bill is not yet law, the scale of the proposed reforms should not be underestimated.  For example, an organisation that has not yet taken action in relation to any one of the mandatory reporting areas will be required to issue an explanation as to why, creating significant reputational risk and regulatory scrutiny for those demonstrating inaction.

Steps organisations can take now

Organisations may wish to review their supply chain operations and existing practices to ensure they have the information necessary to identify and appropriately mitigate modern slavery risks.  Such review may include a deep dive into current risk-assessment processes when engaging new suppliers or renewing existing contracts.  It may also include a thorough review of internal governance procedures, such as existing policies and training programmes, with a view to identifying areas where further controls may be required.

Organisations may also wish to check existing contracts for audit rights, as well as provisions requiring the supply of information.  This will provide crucial visibility into the supply chain which can be used for risk-assessment purposes.  Organisations that supply to the public sector should also be prepared for enhanced due diligence during any public procurement processes.

Key takeaways

The proposed reforms signal a shift from a largely transparency-focussed regime to one with a real emphasis on accountability.  Organisations should use this time to review their current compliance frameworks and ensure that these can withstand any incoming enhanced obligations.

Further information

You can find further details on the Immigration and Asylum Bill here.