Standards and reporting
Modern Slavery Statement
A modern slavery statement is an annual account of steps taken under a defined legal route, so preparation must connect the organisation, reporting year, actions and approved publication.
What does section 54 require?
A commercial organisation within the statutory conditions must prepare a slavery and human-trafficking statement for each financial year Modern Slavery Act 2015 section 54(1)–(4).
Module 01 / 04
Organisation
Identify the commercial organisation and relevant relationships.
Module 02 / 04
Year
Identify the financial year described.
Module 03 / 04
Steps
State what was actually done in the business and supply chains.
Module 04 / 04
Publication
Arrange the required approval, signature and access.
Read the detailed guidance and evidence
The statement is not a certificate that modern slavery is absent from every supplier, and its existence does not establish that each action described was effective.
The standards overview distinguishes statements, standards and claims, while the ESRS value-chain workers guide addresses a separate reporting framework.
Which conditions should be checked before assigning a statement owner?
Read the legal form, UK business connection and turnover test together rather than assume the duty concerns only UK-incorporated companies.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Legal form | Body corporate or qualifying partnership | Whether the statutory organisation definition applies |
| UK connection | Business or part of a business carried on in the UK | Whether the relevant territorial connection exists |
| Supply | Goods or services supplied | Whether the section 54 condition is satisfied |
| Turnover | Organisation plus relevant subsidiary turnover | Whether the prescribed threshold is met |
Read the detailed guidance and evidence
The £36 million amount is prescribed by SI 2015/1833, which also defines total turnover including subsidiary undertakings, rather than appearing as a number in section 54 itself Regulations 2–3.
The Home Office publication guidance gives a practical summary, but the Act and regulations remain the provisions supporting the conclusion Annual statement guidance.
Are LLPs or overseas organisations automatically outside scope?
The statutory definition reaches bodies corporate wherever incorporated with the relevant UK business connection, and an LLP is a body corporate rather than being caught through the partnership label Section 54(12) LLP Act section 1(2) and (5).
Module 01 / 04
Entity
Identify the body making the statement.
Module 02 / 04
Relationship
Identify relevant subsidiaries and group connections.
Module 03 / 04
Activity
Assess the actual UK business connection.
Module 04 / 04
Conclusion
Retain the supported scope decision and reviewer.
Read the detailed guidance and evidence
A group should not assume that one website publication answers every entity question without checking which organisations and financial years the statement covers.
An organisation below its own statutory threshold may still receive supplier-evidence requests from a customer preparing a statement, which is a separate commercial task.
The CSDDD guide explains why a UK statement assessment cannot be substituted for an EU corporate due-diligence scope review.
Are the six suggested content areas mandatory?
Section 54(5) says the statement may include the listed information, while the underlying statement obligation remains defined separately.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Structure and policies | Actual organisational arrangements | Whether the account describes the relevant business |
| Due diligence and risk | Activities actually performed | Whether claims can be supported by evidence |
| Effectiveness | Measures and their limitations | Whether results are described honestly |
| Training | Who received what and for what purpose | Whether attendance is confused with effectiveness |
Read the detailed guidance and evidence
The Home Office practical guide helps structure a useful account, but the suggested areas should not be described as six separate statutory content mandates Section 54(5) Practical guide.
An organisation should avoid replacing a substantive account of its steps with headings that merely reproduce the guidance.
How should a fictional organisation test its draft claims?
Fictional case: Stonemere Hospitality’s draft says every labour supplier was checked, but the supporting tracker covers only the suppliers used at its largest locations.
Module 01 / 04
Assertion
Identify the exact claim proposed for publication.
Module 02 / 04
Population
Identify the suppliers and sites actually reviewed.
Module 03 / 04
Evidence
Inspect what the review examined and found.
Module 04 / 04
Correction
Narrow or complete the claim before approval.
Read the detailed guidance and evidence
The problem is not cured by attaching the tracker because the population behind the word “every” is narrower than the statement suggests.
Stonemere should reconcile the labour-supplier population and investigate the omitted relationships before deciding what the annual statement can support.
The Home Office guidance warns against relying on audits alone, so an audit label cannot by itself close the coverage or effectiveness question Practical guide, audits and inspections.
What evidence would improve Stonemere’s account?
This original fictional review distinguishes records of activity from evidence about what the activity achieved.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Supplier review | Population and questions actually covered | A claim limited to the reviewed relationships |
| Audit report | Period, locations and procedures | Understanding of the audit’s actual coverage |
| Worker concern | Source, investigation and response | A supported description of the issue and action |
| Training record | Attendance, content and follow-up | A claim about delivered training without invented outcomes |
Read the detailed guidance and evidence
A training session or policy acknowledgement can be reported as an action without claiming it proves the absence of abuse.
The evidence review should preserve unresolved concerns rather than turn a missing or conflicting record into a clean supplier result.
Who must approve and sign the statement?
Section 54 sets approval and signature arrangements by organisational form, which should be checked against the actual entity rather than treated as a universal marketing sign-off Section 54(6).
Module 01 / 04
Version
Identify the draft being approved.
Module 02 / 04
Evidence
Make consequential limitations visible to the approving body.
Module 03 / 04
Authority
Check the approval and signatory requirements for the form.
Module 04 / 04
Record
Retain the approved wording and publication version.
Read the detailed guidance and evidence
Stonemere’s board paper should identify the corrected supplier-coverage statement and any remaining limitation, rather than only request approval of a polished design.
The approved document and website version should match, including any later correction to the account of steps taken.
The UK SRS for boards guide develops the wider evidence-challenge problem, without implying that the two reporting routes share identical approval rules.
What should be checked when the statement is published?
Website access and the voluntary registry are separate publication decisions.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Organisation website | Statement and prominent homepage link | The section 54 publication route |
| No website | The statutory request process | How a copy will be supplied where applicable |
| Government registry | Accepted statement and relevant information | A voluntary additional publication route |
| Version consistency | Website and registry documents | Whether readers encounter the same approved account |
Read the detailed guidance and evidence
Section 54(7)–(8) supplies the website or request mechanism, while the registry and Home Office guidance encourage adding a statement rather than making registry submission an existing statutory filing duty Section 54(7)–(8) Registry service Annual statement guidance.
Does the registry’s reporting-year convention set a legal deadline?
Keep the registry process and guidance conventions distinct from the wording of the statutory duty Registry submission process Section 54.
Module 01 / 04
Financial year
Identify the year the statement describes.
Module 02 / 04
Publication
Record the actual approved publication date.
Module 03 / 04
Registry year
Use the service’s convention for that submission.
Module 04 / 04
Status
Distinguish current requirements from policy intentions.
Read the detailed guidance and evidence
The registry process explains its own year convention and optional summary questions, which should not be promoted into additional mandatory statutory statement topics Registry process guidance.
The historical government response records policy intentions, but it does not replace the current Act with a future mandatory-registry or single-deadline regime Government response, historical policy source.
A current-law review is necessary before describing any proposed reform as already applying.
What must remain distinct from the section 54 statement?
Shared supplier information can support several outputs without making their purposes or applicability identical.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Customer questionnaire | Specific customer evidence request | A contractual response rather than automatic statutory scope |
| Government procurement | Buyer’s identified procurement questions | The separate PPN context and applicable requirements |
| Corporate annual report | Human-rights information where the company-law provisions apply | A separate reporting basis and location |
| EU due diligence | Scope and process under the relevant directive | A distinct legal assessment rather than statement equivalence |
Read the detailed guidance and evidence
Cabinet Office PPN 009 addresses government supply-chain procurement, while Companies Act section 414CB has its own scope and reporting content, so neither should be collapsed into a universal section 54 template PPN 009 guidance Companies Act section 414CB.
What would a useful original statement-evidence register contain?
A claim-to-evidence register can make the approval review practical without becoming a supplier certification scheme.
Module 01 / 04
Claim
Exact statement wording and intended coverage.
Module 02 / 04
Evidence
Source, period, population and limitation.
Module 03 / 04
Review
Challenge, decision and responsible owner.
Module 04 / 04
Publication
Approved wording and location.
Read the detailed guidance and evidence
Stonemere’s planned register would show the initial “every supplier” claim, the discovered population gap and the corrected approved statement.
Sensitive worker information should be referenced through controlled records rather than copied into a workbook circulated with a public-report draft.
A software RFP should test whether a revised claim preserves the source and earlier reviewer challenge.
Which assertions deserve a final wording challenge?
Make the final account proportionate to the evidence and avoid unsupported assurance language.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| “All suppliers checked” | Reconciled supplier population | Does the stated coverage match the actual work? |
| “No modern slavery” | Scope and limits of the evidence | Is the claim stronger than the investigation supports? |
| “Audited and compliant” | Actual audit and legal-basis assessment | Are distinct conclusions being conflated? |
| “Registry filing mandatory” | Current law and registry guidance | Has a future intention been mistaken for an operative rule? |
Read the detailed guidance and evidence
The Act’s statement duty and permissive content list do not require a particular audit scheme, rating or certification Section 54(4)–(5) Practical guide.
A consultancy brief should specify statement preparation and evidence review without promising that drafting proves the absence of exploitation.
What if evidence changes after board approval?
Compare the final published account with the approved wording and assess the consequence of a newly discovered limitation.
Module 01 / 04
Discovery
Identify the new fact and the assertion affected.
Module 02 / 04
Consequence
Assess whether the current wording remains supported.
Module 03 / 04
Approval
Resolve the appropriate review of revised wording.
Module 04 / 04
Publication
Keep website and registry versions consistent.
Read the detailed guidance and evidence
Stonemere discovers after approval that a supplier review described in the draft took place outside the financial year the statement covers.
The report owner should resolve the timing and wording with the appropriate approving team rather than leave a misleading account because the publication design is finished.
Retain the actual approved and published versions so the section 54 approval and publication record can be reconstructed Section 54(6)–(8).
How can the team prepare a reviewable evidence file?
This editorial workflow organises preparation without certifying compliance or replacing a statutory process.
- 101
Assess the organisation
Check form, UK activity and turnover basis. - 202
Set the period
Identify the financial year and statement population. - 303
Collect the steps
Record what was actually done. - 404
Reconcile coverage
Check suppliers, sites and group entities described. - 505
Review effectiveness claims
Read evidence and limitations behind outcomes. - 606
Resolve the draft
Correct broad or unsupported statements. - 707
Approve and sign
Use the applicable organisational requirements. - 808
Publish accessibly
Check the website route and any voluntary registry entry. - 909
Retain the record
Preserve approved wording, evidence and subsequent corrections.
Frequently asked
Questions people ask
Who must publish a modern slavery statement?
Assess the commercial-organisation, UK-business, goods/services and turnover conditions together.
Is the turnover threshold in the Act?
The £36 million amount and turnover calculation are set in the regulations rather than stated as a figure in section 54.
Are the six content areas legally mandatory?
Section 54(5) says the statement may include those areas, which is different from six mandatory content duties.
Must we use the government registry?
The current registry and guidance encourage submission as an additional route, separate from the statutory website-publication duty.
Does an audit prove the statement is accurate?
No, review its scope and limitations and avoid relying on audits alone.
Are LLPs automatically excluded?
No, an LLP is a body corporate and must be assessed against the section 54 conditions.
Sources
Primary sources
Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.
- UK legislationModern Slavery Act 2015, section 54
- UK legislationTransparency in Supply Chains Regulations 2015
- Home OfficeTransparency in supply chains: a practical guide
- Home OfficePublish an annual modern slavery statement
- Home OfficeModern slavery statement registry
- Home OfficeProcess for submitting a statement to the registry
- Home OfficeTransparency in supply chains: government response, 2020
- UK legislationLimited Liability Partnerships Act 2000, section 1
- Cabinet OfficePPN 009 guidance on modern slavery in government supply chains
- UK legislationCompanies Act 2006, section 414CB