How to prepare a Modern Slavery Statement, and what suppliers will be asked for
Updated: Oct 17
If your organisation reports under the Modern Slavery Act 2018 and your financial year ended on 30 June, your statement is due by 31 December 2026.
Last updated: 16 October 2026
This guide covers what the Act requires, how the statement must be approved and lodged, and what the Attorney-General's Department's March 2026 guidance says good practice looks like. It is written for two readers: the teams preparing a statement, and the suppliers they will ask for evidence.
The government has also proposed turning the Act from a reporting law into a duty to prevent. Our explainer on the proposed reforms covers that. This guide deals with what applies today.
What is a modern slavery statement?
A modern slavery statement is an annual public report under the Modern Slavery Act 2018 (Cth). It describes the modern slavery risks in an organisation's operations and supply chains, and what the organisation is doing about them.
Statements are lodged with the Attorney-General's Department and published on the online Modern Slavery Statements Register, where anyone can read them. On 16 October 2026 the Register listed 18,869 statements, a figure it describes as indicative.
The Act does not ask you to certify that your supply chain is free of modern slavery. The department's guidance says such a guarantee is very difficult to give. What the Act asks for is a clear account of your risks and the steps you are taking to find and address them.
Who has to submit one?
You must report if your entity has consolidated revenue of at least A$100 million for the reporting period and is an Australian entity or carries on business in Australia.
Consolidated revenue is your total revenue, combined with the revenue of any entities you control, calculated under the accounting standards.
Some Commonwealth bodies with that revenue are also covered.
Groups can lodge a joint statement covering several reporting entities.
If you are below the threshold, you can report voluntarily. You give the Minister written notice, in the approved form, before the end of the reporting period. You can stop by giving notice before a period starts.
Organisations below A$100 million have no direct obligation. They may still be asked for modern slavery evidence by customers who do report, which is covered further down.
When is it due?
Within six months after the end of your reporting period. Your reporting period is your financial year or other annual accounting period.
Reporting period ends | Statement due by |
30 June | 31 December |
31 December | 30 June |
31 March | 30 September |
You need a statement for every reporting period, so this is an annual cycle, not a one-off.
What must it include?
Section 16 of the Act sets seven mandatory criteria. Every statement must address each one.
Identify the reporting entity.
Describe its structure, operations and supply chains.
Describe the modern slavery risks in its operations and supply chains, and in those of any entities it owns or controls.
Describe the actions taken to assess and address those risks, including due diligence and remediation.
Describe how it assesses whether those actions are effective.
Describe how it consulted the entities it owns or controls. A joint statement also describes consultation with each entity it covers.
Include any other relevant information.
The Register's Statement Annexure lists the page numbers where your statement addresses each criterion. If you own or control no other entities, say so explicitly for criterion 6 rather than leaving it out.
Criteria 1 and 2 are mostly factual. Criteria 3, 4 and 5 take the most work, and the March 2026 guidance gives worked examples for each.
How do you show your working on risks, actions and effectiveness?
In March 2026 the Attorney-General's Department published one-page guidance sheets with good-practice, compliant and non-compliant examples for criteria 3 to 6. Their common message is to show your working: say what you looked at, what you found and why you reached your conclusions.
Criterion | What the guidance looks for | What it treats as non-compliant |
3. Risks | Risks to people, not business risk. The factors behind each risk: sector and industry, products and services, geography, and your own operations and entities. Any risk rating backed by the reasons for it. Honest limits, such as poor visibility beyond direct suppliers. | A bare "low risk" rating with no reasons. General statements opposing modern slavery. |
4. Actions | Specific actions taken during the reporting period, including due diligence and remediation. Better statements reference the six due diligence steps in the UN Guiding Principles on Business and Human Rights. | Generic references to "due diligence" that don't say what it involved. Plans for future years presented as this year's action. |
5. Effectiveness | How you check that your actions work, using measures such as training completion, contracts carrying modern slavery clauses, grievances received and cases remediated. Good practice measures outcomes for workers, not just activity. | Saying no modern slavery was found. A promise to assess effectiveness in future. |
6. Consultation | How you consulted the entities you own or control. If you own or control none, saying so. | Statements that give no detail of how consultation happened. Treating consultation with industry peers or NGOs as meeting this criterion. |
Two points stand out. First, if you are early in your response, the guidance says to be honest about it and describe the steps you have taken, such as mapping risks or setting a roadmap. Second, "we found no modern slavery" is not evidence that your actions work. Criterion 5 asks how you measure effectiveness, not what you did or didn't find.
How must it be approved and signed?
The department's March 2026 guidance says a statement that doesn't meet the approval and signing requirements may not be published on the Register.
Approval. A single entity's statement must be approved by its principal governing body, which for most companies is the board. The statement must say so. Approval cannot be delegated to an individual, an executive committee or a sub-committee.
Works: "This statement was approved by the board of directors of [Entity], in its capacity as principal governing body, on [date]."
Doesn't work: "approved by the Executive Leadership Team", "approved by the CEO on behalf of the board", or "approved by selected directors".
The Act doesn't require an approval date, but the guidance recommends including one.
Signature. A responsible member must sign it, usually a director. Put their name and position next to the signature, inside the statement itself rather than in a separate document. Electronic signatures are accepted. A procurement officer, risk officer or general counsel who is not on the board can't sign.
Joint statements have three approval options: each covered entity's board approves; a parent entity's board approves for all of them; or, if neither is practicable, at least one covered entity's board approves and the statement explains why.
How do you lodge it?
You submit the statement through the online Modern Slavery Statements Register, and the department publishes it there.
Standalone document. It must be lodged on its own, not as part of a sustainability or annual report.
Register access. The Register has upgraded its multi-factor authentication, and existing users must re-register their access. Check yours well before the deadline.
Publishing elsewhere. You can also publish it on your website or in your annual report. If you do that before the Register publishes it, note that it is under consideration.
Revisions are for exceptional cases, such as false, misleading or market-sensitive information. A revised statement must show the revision date and what changed.
There is currently no penalty for failing to report. The Minister can ask an entity to explain or fix non-compliance and, if it doesn't, publish its name. The government has said it intends to introduce civil penalties for not meeting reporting obligations.
What does this mean for suppliers?
Suppliers are not required to lodge a statement unless they are reporting entities themselves. Criteria 3, 4 and 5 often rely on information from suppliers, so the questions flow down the supply chain.
The department's own examples of good practice include:
annual supplier questionnaires
suppliers declaring their production sites
modern slavery clauses in supplier contracts
reviewing key suppliers' own statements, and engaging most with higher-risk suppliers
Based on the criteria and those examples, a supplier may be asked for:
Request | What it supports in the customer's statement |
Legal name, country and business identifier (such as an ABN) | Criterion 2, describing the supply chain |
A modern slavery or human rights policy | Criterion 4, actions taken |
A risk assessment covering your own suppliers | Criteria 3 and 4, risks and due diligence |
Agreement to contract clauses (notification, audit, termination) | Criterion 4, actions taken |
Training records, grievance channels and how issues were handled | Criterion 5, effectiveness |
Having these ready, current and signed off means you can answer once and reuse the answer, rather than rebuilding it for every customer questionnaire.
How can you prepare now?
If you report under the Act:
Confirm your reporting period and due date
Check your Register access, including the new multi-factor authentication
Map your structure, operations and supply chains, including entities you own or control
Write the risk section around risks to people, with the reasons behind any rating
List the specific actions taken this reporting period, including due diligence and remediation
Choose measures of effectiveness and report them
Describe consultation with owned or controlled entities, or state that there are none
Book board approval, and have a director sign it inside the statement
If you supply a reporting entity:
Keep your policy, risk assessment, supplier list and contract clauses current and signed off
Record training and how any grievances were handled
Be ready to share it in a form a buyer can check
ESG Verified certification organises this evidence into one structured, buyer-verifiable record, including a Modern Slavery domain. It does not lodge statements or provide legal advice. See the certification levels, or browse our FAQ.
Frequently asked questions
Does my business need to submit a modern slavery statement?
Only if it has consolidated revenue of at least A$100 million and is Australian or carries on business in Australia. Below that, you can report voluntarily, and you may still be asked for evidence by customers who do report.
When is the statement due for a 30 June year-end?
By 31 December, six months after the end of the reporting period.
Can our CEO approve the statement?
Not alone. The principal governing body, usually the board, must approve it, and approval can't be delegated. A CEO who sits on the board can sign it as the responsible member.
Can the statement be part of our annual report?
It must be lodged on the Register as a standalone document. You can also include it in your annual report or publish it on your website.
Is ESG Verified certification the same as a modern slavery statement?
No. Certification doesn't lodge a statement or satisfy the Act for you. It organises the evidence behind one, such as your policy, risk assessment, supplier list and contract clauses, so buyers can check it. See our certification levels.
Sources
All checked 16 October 2026. This article is general information, not legal advice.
Modern Slavery Act 2018 (Cth), Federal Register of Legislation
Modern Slavery Statements Register, Attorney-General's Department
Register resources: Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities (May 2023); supplementary guidance on mandatory criteria three to six, principal governing body approval and signature of a responsible member (March 2026); Modern Slavery Statement Annexure
New criminal offence for failure to prevent modern slavery on the way, Clayton Utz, 17 July 2026
Modern Slavery Act 2018 reforms explained, ESG Verified
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