OUR APPROACH
Three things we help organisations understand clearly
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What the law requires now
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What reform proposals are gaining momentum
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What prudent organisations should do before new obligations arrive
Our view is simple: businesses don't need to wait for legislation to mature their response. They do need to understand the difference between mandatory reporting, proposed due diligence reform, and leading practice.
SECTION 01
What the law requires now
The current Act requires large entities operating in Australia to publish annual modern slavery statements. Those statements must describe the entity's structure, operations and supply chains, the risks of modern slavery in those areas, the actions taken to assess and address those risks, and how the entity assesses the effectiveness of those actions.
For many organisations, that reporting obligation has been the main focus. But reporting alone is no longer enough to satisfy boards, investors, procurement leaders, workers, civil society or regulators.
SECTION 02
What is being proposed
Australia's reform discussion is now focused on strengthening the quality of business response, not simply increasing the number of statements filed. That includes proposals around:
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Stronger compliance settings
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Clearer expectations for action
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A more risk-based approach
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Potential due diligence obligations
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Mechanisms to identify products, services or industries that warrant heightened attention
The direction of travel is clear even where final law is not.
SECTION 02
What organisations should do now
Organisations should use 2026 to close the gap between disclosure and action.
Improving risk identification beyond generic sector descriptions
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Building evidence for decisions made by procurement and management
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Defining escalation thresholds for serious or repeated red flags
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Documenting what "reasonable and proportionate" action looks like in practice
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Preparing governance structures that can support a more formal due diligence model
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