Australia’s Modern Slavery Act Reform: What Businesses Must Know Before September 2025

Modern slavery is not a historical relic. It is embedded in today’s global supply chains, and Australia is no exception. The government estimates that 41,000 people are living in modern slavery conditions in Australia right now.

The Modern Slavery Act 2018 (Cth) was meant to tackle this. But seven years on, the law is outdated and toothless — requiring companies with over A$100 million turnover to report annually, but imposing no penalties for weak or non-compliant statements.

That’s why the government launched a consultation in July 2025 on strengthening the law, with submissions due by 1 September 2025.

The Current Law: Reporting Without Accountability

Under the current framework, businesses must file Modern Slavery Statements covering their:

• Risks of slavery in operations and supply chains
• Actions taken to identify and address those risks
• Assessment of effectiveness

More than 12,500 statements have been filed, representing 20,600 entities across 64 countries. Yet studies show that 12–17% of reports are non-compliant, with no penalties imposed.

Even more concerning, prosecutions are almost non-existent: only five cases in 2023, zero convictions. As Anti-Slavery Commissioner Chris Evans warned, this makes Australia a “dumping ground” for goods made with forced labour while the EU, Canada, and US enforce stricter laws.

Why Reform Is Critical

The government’s consultation paper outlines major changes:

• Civil penalties for failure to report, false or misleading statements, or ignoring remedial requests.
• Mandatory human rights due diligence (HRDD) aligning with the EU Corporate Sustainability Due Diligence Directive (CSDDD).
• Corporate group reporting — replacing confusing joint submissions.
• Regulator powers infringement notices, enforceable undertakings, information gathering, and redaction.
• Expanded disclosures on grievance mechanisms, remediation, and effectiveness tracking.

This shift would bring Australia in line with international peers and move beyond transparency toward accountability.

Timeline: The September 1, 2025 Deadline

The public consultation on strengthening the Modern Slavery Act is open until 1 September 2025. After this, reforms could move quickly into legislation.

For businesses, this is the last window to influence the law — and the moment to start aligning compliance programs with HRDD standards, before obligations and penalties take effect.

Business Implications: Why Acting Now Matters

For companies operating in Australia, waiting until reforms pass is risky. The direction of travel is clear — human rights due diligence is becoming law worldwide. Businesses that prepare now will:

• Stay competitive in markets where HRDD is already required (EU, Canada, US).
• Build resilient supply chains less vulnerable to disruption or scandal.
• Reduce reputational and litigation risks.
• Meet growing investor and ESG compliance expectations.

💡 If your business is still using spreadsheets and ad hoc reporting, you’ll struggle when HRDD becomes mandatory. Investing in structured supply chain compliance solutions and human rights due diligence frameworks now will help you stay ahead.