Modern Slavery Act compliance for Australian entities
The Modern Slavery Act 2018 (Cth) requires Australian entities with annual consolidated revenue of at least $100 million to publish an annual modern slavery statement. The statement must address seven mandatory criteria including risks in operations and supply chains. This guide sets out 10 core obligations.
Coverage
Australian entities (including incorporated and unincorporated) with annual consolidated revenue of at least $100 million. Voluntary reporting by smaller entities is permitted and increasingly common in supply chain due diligence.
Legal basis
The Modern Slavery Act 2018 (Cth) and the Commonwealth Modern Slavery Statements Register operated by the Attorney-General's Department.
The obligations
Determine if reporting is required
Calculate annual consolidated revenue. If at least $100 million in the reporting period, the entity is a reporting entity under the Act.
Identify the reporting period
The reporting period aligns with the entity's financial year. The statement must be published within 6 months after the end of the reporting period.
Address the structure, operations, and supply chains
The statement must describe the entity's structure, operations, and supply chains.
Identify modern slavery risks
Describe the risks of modern slavery practices in the operations and supply chains, including from any entities the reporting entity owns or controls.
Describe actions taken to assess and address risks
Describe the due diligence and remediation processes used to assess and address modern slavery risks.
Assess effectiveness of actions
Describe how the entity assesses the effectiveness of the actions taken to address modern slavery risks.
Describe consultation
Describe the process of consultation with any entities the reporting entity owns or controls (and entities preparing joint statements).
Provide any other relevant information
Include any other information considered relevant by the reporting entity. This is a mandatory criterion even if the answer is "no other information".
Approve the statement
The statement must be approved by the principal governing body of the entity (typically the board of directors) and signed by a responsible member.
Publish on the register
Submit the approved statement to the Commonwealth Modern Slavery Statements Register within 6 months after the end of the reporting period.
What happens if you do not comply
The current federal Modern Slavery Act does not impose civil or criminal penalties for failure to report — but reputational and stakeholder pressure are substantial. Recent reform proposals would introduce penalties.
Reporting requirements
Annual modern slavery statement, published on the Commonwealth Modern Slavery Statements Register within 6 months after the end of the reporting period. Statements are publicly accessible.
What firms should do today
- Map the supply chain at least to the first tier (direct suppliers)
- Conduct a modern slavery risk assessment of high-risk supply chain segments
- Update procurement contracts to include modern slavery clauses
- Train procurement and sourcing staff on modern slavery risks
- Establish a process for handling modern slavery complaints or concerns
- Coordinate the statement with controlled entities to enable a joint statement
Compliance with Quillio
Quillio supports modern slavery compliance by drafting modern slavery statements, conducting risk assessments of supply chain documentation, and tracking the statement preparation across reporting cycles. See /practice-areas/commercial-lawyers or start a free trial.
This guide is general information about Modern Slavery Act obligations — not legal or compliance advice. Always obtain specialist advice for preparing and approving modern slavery statements.
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