The Modern Slavery Act 2018 Review: What businesses need to know

9 December 2025

The Modern Slavery Act 2018 is an important element of the legislative environment in which large firms operate. It requires large businesses in Australia to report on how they identify and manage the risks of modern slavery in their own operations and in their supply chain.

Prevention of modern slavery is – like most sustainability-related endeavours – preferable to (and cheaper than!) remediation. The impacts of discovering modern slavery may include:

  • Consumer backlash
  • Costly internal investigations and legal counsel
  • Reformulation of supply chains to remove flagged components
  • Deep engagement to remove the occurrence of modern slavery from supply chain nodes

The Act is currently being reviewed, and the changes proposed will have a significant impact on the obligations of reporting companies. Australian investors are highly engaged with the issue of modern slavery, so it’s important to keep abreast of the future direction of this legislation.

In our latest article, Sophie Schlachter, Sustainability Advisor, explores the story of the Act so far, the proposed changes, and how Australian businesses should prepare using a connected and sustainable business planning approach.

Modern Slavery Act 2018: The story so far

  • The Act came into force on January 2019, establishing a reporting obligation for companies with an annual revenue of $100 million AUD+
  • A planned three-year post-implementation review has occurred, with 30 recommendations being made and 25 of those being accepted in principle by the Government
  • Financial consultation on proposed changes occurred July– September 2025
  • Legislation changes could pass both houses of parliament by late 2026

What changes are proposed?

  1. Reporting criteria: more detail to be required on the grievance mechanisms that businesses have in place, and the actions being taken to remediate modern slavery incidents when they occur
  2. Due diligence requirement: beyond just reporting, companies will have to conduct due diligence activities (See next slide)
  3. High risk declarations: the government may declare certain products, countries or industries to be generally “high risk”, requiring companies to address those supply chain nodes specifically in reporting
  4. Penalty framework: financial or civil penalties are being discussed, for failing to report or for misleading or false statements

Due diligence – the core shift

  • The proposed changes would see the current Act shift from reporting-type legislation, to due diligence-type legislation
  • Due diligence-type legislation is stronger than reporting-type legislation, and requires companies to take ownership of the issue, usually through the whole value chain
  • There are fewer options to “opt-out” of requirements, and the focus goes beyond transparency to accountability and action
  • Companies bound by this type of legislation must; commit, embed, assess, engage and report on modern slavery risks

Bringing modern slavery data into enterprise planning

Being able to comply with due diligence obligations requires businesses to take a systemic approach to the issue of modern slavery, based on robust risk assessments informed by the best available data.

At Zooss, we specialise in bringing clarity to business planning and reporting using data analytics.

In our Sustainable Business Planning approach, modern slavery data is incorporated into S&OP and financial planning models to generate dynamic insights into the risk profile of products and ensuring a holistic assessment of risk management activities.

By adopting this connected and sustainable planning approach, businesses can predict and improve social impact outcomes, decrease non-compliance risk, strengthen disclosure integrity, and increase customer and investor confidence.

Find out more

About the author – Sophie Schlachter, Sustainability Advisor

Sophie holds a Master of Sustainability from the University of Sydney and has worked across regenerative agriculture and waste management sectors, including for OzHarvest and the Taronga Zoo Conservation Society. Sophie is experienced in business and sustainability analytics, and is passionate about enabling sustainable business that balances profit with positive environmental and social outcomes.

Better Planning. Better Planet.

 

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