≥$100M revenue reporters
Modern Slavery hub
Annual Modern Slavery Statement against 7 mandatory criteria, due within 6 months of FY end. Anti-Slavery Commissioner now active; reformed regime under McMillan Review brings civil penalties for non-publication.
The Modern Slavery Act 2018 requires reporting entities (consolidated revenue ≥$100M) to publish an annual Modern Slavery Statement addressing 7 mandatory criteria. ~3,000 entities currently in scope; statements published in the Modern Slavery Register.
From 2024, the Federal Anti-Slavery Commissioner is operational. The McMillan Statutory Review recommended significant reforms including: lower the reporting threshold ($50M proposed), introduce a due diligence obligation, introduce civil penalties for non-publication, require detail on actions taken (not just risks identified).
NSW has its own Modern Slavery Act 2018 with the NSW Anti-Slavery Commissioner (separate from the federal scheme). Some state government procurement requires NSW reporting regardless of federal threshold.
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FAQ
Am I a reporting entity?
If your group's consolidated revenue is ≥$100M for the financial year. Foreign entities with Australian operations + Australian-incorporated subsidiaries can both be in scope. Voluntary statements are welcome from smaller entities.
When is my statement due?
Within 6 months of the end of your reporting period (financial year). For a 30 June year-end, the statement is due by 31 December. For a 31 December year-end, due by 30 June following.
What are the 7 mandatory criteria?
(1) Identify reporting entity, (2) describe structure operations + supply chains, (3) describe modern slavery risks, (4) describe actions to assess + address risks, (5) describe effectiveness of actions, (6) describe consultation with controlled entities, (7) any other relevant information. Signed off by the principal governing body.
What's a 'principal governing body' approval?
The Board (or equivalent) must approve the statement. Sign-off is by a director or principal officer. Joint statements (multiple entities) need approval from each entity's principal governing body.
What's the Anti-Slavery Commissioner doing?
Federal Commissioner appointed 2024. Operates separately from statement compliance — has investigation powers, can issue compliance notices, publishes guidance + advice. Engages with reporting entities on best-practice statements.
Are there penalties for non-publication?
Currently no civil penalties under federal Act — only naming + shaming via the Register. McMillan Review recommended civil penalties; legislation pending. NSW Act has civil penalties already.
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