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Modern Slavery Reporting​

If you are responsible for procurement, legal risk, sustainability, governance or reporting, the hardest part is not finding information. It is separating current obligations from likely next steps.

This page is designed to do exactly that.

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At ESG Impact, we help organisations understand three things clearly:

• what the law requires now

• what reform proposals are gaining momentum

• what prudent organisations should do before new obligations arrive

Our view is simple: businesses do not 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.

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Section: 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.

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Section: 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:

• stronger compliance settings

• clearer expectations for action

• a more risk-based approach

• potential due diligence obligations

• mechanisms to identify products, services or industries that warrant heightened attention

The direction of travel is clear even where final law is not.

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Section: What organisations should do now

Organisations should use 2026 to close the gap between disclosure and action.

That means:

• improving risk identification beyond generic sector descriptions

• building evidence for decisions made by procurement and management

• defining escalation thresholds for serious or repeated red flags

• documenting what “reasonable and proportionate” action looks like in practice

• preparing governance structures that can support a more formal due diligence model

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Next Steps:

Need a practical view of reform risk?
ESG Impact helps boards, legal teams and procurement leaders interpret reform developments and translate them into proportionate, workable action.

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