Modern Slavery Legislation

Canada Legislation:
Canada has progressively strengthened its regulatory approach to forced labour in supply chains. Since July 2020, amendments to the Customs Tariff Act have prohibited imports produced wholly or partly using forced labour. On 1 January 2024, this prohibition was expanded to include goods associated with child labour. Bill C-35 was introduced in June 2026 to establish a standalone border enforcement framework, although it remains before Parliament.

This framework was further expanded through the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211). The legislation was enacted in May 2023 and came into force on 1 January 2024. It requires certain entities and government institutions to report annually on steps taken to prevent and reduce forced and child labour risks within their operations and supply chains. Specified offences may result in financial penalties of up to CAD 250,000.

United States Legislation:
In the United States, modern slavery risks within supply chains are addressed through a combination of disclosure requirements and trade enforcement measures. At the state level, California’s Transparency in Supply Chains Act requires companies above a defined revenue threshold to publicly report on the steps they take to address human trafficking and forced labour risks. This applies specifically to their direct supply chains.

At the federal level, enforcement mechanisms extend beyond disclosure. The Tariff Act of 1930 authorises U.S. Customs and Border Protection to detain goods at the border through the use of Withhold Release Orders. This applies where there is reasonable evidence that forced or indentured labour has been used in production.

These measures were further strengthened with the introduction of the Uyghur Forced Labour Prevention Act in 2021. The legislation establishes a presumption that goods linked to the Xinjiang Uyghur Autonomous Region are produced using forced labour, placing the burden of proof on importers to demonstrate otherwise. This approach significantly elevates expectations for supply chain traceability, due diligence, and evidence-based risk management for organisations importing goods into the United States.

United Kingdom Legislation:

The United Kingdom’s Modern Slavery Act 2015 consolidated existing offences relating to slavery, servitude, and human trafficking, while also expanding enforcement powers available to the courts. These powers include the ability to issue prevention and risk orders, confiscate assets connected to exploitative conduct, and strengthen protections for victims. The Act also established the Independent Anti-Slavery Commissioner to support improved coordination, consistency, and effectiveness in prevention and detection efforts.

In addition to enforcement measures, the legislation introduced a transparency requirement for organisations exceeding a specified turnover threshold. These entities are required to publish an annual statement outlining the steps taken to identify and address modern slavery risks within their operations and supply chains. While the transparency obligation is not currently supported by financial penalties, an independent review conducted in 2019 recommended reforms to strengthen compliance and enforcement. It noted the relative robustness of more recent regimes, including Australia’s mandatory reporting framework.

Australian Legislation:
Australia’s Modern Slavery Act 2018 establishes mandatory reporting obligations for entities with consolidated annual revenue of AUD 100 million or more. In-scope organisations must prepare annual statements explaining how modern slavery risks are identified, assessed, and addressed across their operations and supply chains. These statements are published on the Australian Government’s publicly accessible Modern Slavery Statements Register, supporting transparency and stakeholder scrutiny.

The legislation does not currently include financial penalties for non-compliance, although organisations may still face reputational harm and greater attention from investors, customers, and regulators. Following a statutory review, the Australian Government released its response in December 2024. It agreed fully, partly, or in principle with 25 of the 30 recommendations. Proposed reforms include civil penalties and additional reporting requirements, but these changes have not yet been enacted.

New Zealand Legislation:
In April 2022, the New Zealand Government released draft legislation indicating an intention to strengthen its response to modern slavery and broader forms of worker exploitation. The proposed framework signals a shift toward more proactive obligations. It requires organisations to take reasonable and proportionate steps to identify and address modern slavery risks within both domestic operations and international supply chains.

Under the draft approach, reporting obligations would apply on a tiered basis. Medium and large organisations would be required to publicly disclose the measures they have taken to prevent modern slavery. Larger entities would also face additional expectations to undertake formal due diligence processes. These processes would include identifying, assessing, and mitigating modern slavery risks, reinforcing accountability and aligning New Zealand’s approach more closely with emerging international standards.

European Legislation:

In 2024, the European Parliament introduced the Forced Labour Regulation (FLR), significantly strengthening the European Union’s ability to restrict goods produced using forced labour. It applies to goods entering, circulating within, or being exported from the EU market. The regulation empowers authorities to investigate suspected forced labour, prohibit the sale, import, or export of affected goods, and require their removal from the EU market.

Failure to comply with the regulation may trigger enforcement action, including financial penalties, sanctions, and potential exclusion from public procurement processes. The FLR represents a shift toward stronger, trade-based enforcement. It also increases expectations for supply chain traceability, due diligence, and evidence-based risk management for organisations operating within or trading with the EU.

France Legislation:

France’s Corporate Duty of Vigilance Law, introduced in 2017, imposes mandatory due diligence obligations on large companies operating in France. In-scope entities are required to develop, implement, and publicly disclose a vigilance plan. This plan outlines the measures in place to identify, prevent, and mitigate human rights and environmental risks across their own operations and throughout their supply chains.

Non-compliance with these requirements may expose organisations to legal proceedings and financial sanctions. The law reinforces expectations that businesses adopt a proactive and ongoing approach to risk management. This approach should be supported by documented processes, effective oversight, and demonstrable action to address identified risks.

Germany Legislation:

Germany’s Supply Chain Due Diligence Act, adopted in 2021 and in force from 2023, establishes mandatory human rights and environmental due diligence obligations for large organisations operating in Germany. The legislation requires in-scope entities to identify, prevent, and report on risks across their own operations and supply chains. This includes risks related to forced labour and child labour. From 2024, the scope of the Act expanded to include organisations with a lower employee threshold, significantly broadening its application.

Failure to comply with the Act can result in substantial financial penalties and exclusion from public procurement processes in Germany. These enforcement measures reinforce expectations that organisations implement ongoing, systematic due diligence processes. They also require organisations to maintain active oversight of supply chain risks.

Norway Legislation:

Norway’s Transparency Act, which came into effect in July 2022, introduces mandatory human rights due diligence obligations for companies meeting defined size thresholds. In-scope organisations are required to conduct annual assessments of human rights risks across their own operations and supply chains. They must also publicly disclose how those risks are identified, managed, and addressed.

A key feature of the Act is its emphasis on transparency and stakeholder access to information. Individuals are granted the right to request details about a company’s human rights impacts and the measures in place to prevent or mitigate harm. This requirement reinforces expectations for documented due diligence processes, clear accountability, and the ability to substantiate actions taken in response to identified risks.