Modern Slavery Statement playbook for Australian manufacturers
The full obligation stack for an Australian-revenue manufacturer over the $100M consolidated revenue threshold — the seven mandatory criteria under s 16 of the Modern Slavery Act 2018 (Cth), supply chain mapping by tier, risk assessment, action verification, effectiveness measures, board approval, the 6-month statement deadline and the public register.
Key deadlines — next 12 months
- 31 December 2026Modern Slavery Statement (FY26 ending 30 June)
- 31 December 2027Modern Slavery Statement (FY27)
- Within 6 months of FY-endStanding statement deadline
Does this apply to me?
Answer yes to any of the below and the obligations in this playbook are likely relevant.
- 1Is your entity an Australian entity, or carrying on business in Australia, with consolidated revenue of AUD $100M or more in the reporting period?
- 2Do you manufacture, source, or assemble goods involving raw materials, components or labour from higher-risk jurisdictions (cotton, electronics, solar PV, rubber, leather, bricks, garments)?
- 3Does your group structure include foreign subsidiaries or joint ventures that procure inputs?
- 4Do you sell to or supply NSW Government agencies (NSW Modern Slavery Act 2018 — separate regime)?
- 5Do you procure goods from higher-risk regions such as Xinjiang, Bangladesh, India, China or Vietnam?
Plain English summary
The Modern Slavery Act 2018 (Cth) requires reporting entities with consolidated revenue of at least AUD $100M to publish an annual Modern Slavery Statement addressing seven mandatory criteria. Statements are lodged on the public Modern Slavery Statements Register within 6 months of the end of the reporting period and approved by the principal governing body.
For manufacturers, the regime is harder than for service businesses. Manufacturing supply chains span multiple tiers (Tier 1 direct suppliers, Tier 2 component makers, Tier 3 raw material producers). The 7 mandatory criteria in s 16 require not just describing the supply chain but assessing risks within it, identifying actions to address those risks, and measuring effectiveness over time. Year-one statements are forgiven for being descriptive; year-three statements are expected to show maturity.
The 2023 McMillan Review of the Modern Slavery Act recommended civil penalties for non-publication and false statements, an Anti-Slavery Commissioner with investigative powers, and lowering the revenue threshold to $50M. The Anti-Slavery Commissioner role was operationalised in 2024 and has begun publishing thematic reviews. The Modern Slavery Amendment Bill 2024 (introducing civil penalties) is before Parliament. NSW already has a separate regime with its own NSW Anti-Slavery Commissioner.
This playbook walks through every obligation a manufacturer faces, the section of the Modern Slavery Act it sits under, who in the firm is accountable, the cadence, the penalty, and the regulator-direct source. Use the Modern Slavery threshold checker and the Modern Slavery Statement scaffold for the practical pieces.
Obligation checklist
Every obligation cites the Act and section. Source URLs link to the regulator's portal — Rules Mate does not republish statutory text.
- 1
Modern Slavery Act 2018 (Cth), s 5 (reporting entity)
Confirm reporting entity status: an Australian entity, or entity carrying on business in Australia, with consolidated revenue of AUD $100M or more for the reporting period. Volunteer reporting is permitted below the threshold.
- Who's responsible
- CFO + Company Secretary
- Frequency
- At end of each financial year
- Penalty
- Civil penalties proposed under the Modern Slavery Amendment Bill 2024; reputational + procurement-eligibility risk.
- Source
- Regulator-direct link
- 2
Modern Slavery Act 2018 (Cth), s 16(1)(a) — Mandatory criterion 1
Describe the reporting entity (legal structure, ABN/ACN, locations, sectors).
- Who's responsible
- Company Secretary
- Frequency
- Annual
- Penalty
- Statement non-compliance — published on register; possible civil penalty under proposed bill.
- Source
- Regulator-direct link
- 3
Modern Slavery Act 2018 (Cth), s 16(1)(b) — Mandatory criterion 2
Describe the structure, operations and supply chains of the reporting entity. For manufacturers, this means a tier-mapped description of suppliers (Tier 1 direct, Tier 2 sub-suppliers, Tier 3 raw materials/labour brokers).
- Who's responsible
- Head of Procurement + Operations
- Frequency
- Annual
- Penalty
- As above.
- Source
- Regulator-direct link
- 4
Modern Slavery Act 2018 (Cth), s 16(1)(c) — Mandatory criterion 3
Describe modern slavery risks in operations and supply chains. Risk-by-tier: sector (textiles, electronics, leather, bricks), geography (high-risk countries), product (cotton, palm oil, mica), entity (labour-broker dependence). Use Global Slavery Index + Walk Free + US TVPRA + UN Guiding Principles risk indicators.
- Who's responsible
- Head of ESG / Risk + Procurement
- Frequency
- Annual
- Penalty
- As above.
- Source
- Regulator-direct link
- 5
Modern Slavery Act 2018 (Cth), s 16(1)(d) — Mandatory criterion 4
Describe actions taken to assess and address those risks — including due diligence and remediation processes. Year-1 statements are scoped to design; Year-3+ statements should show worker-voice channels, supplier audits, remediation triggers, code of conduct rollout.
- Who's responsible
- Head of ESG + Procurement + Legal
- Frequency
- Annual
- Penalty
- As above; year-on-year regression flagged by Anti-Slavery Commissioner thematic reviews.
- Source
- Regulator-direct link
- 6
Modern Slavery Act 2018 (Cth), s 16(1)(e) — Mandatory criterion 5
Describe how the reporting entity assesses the effectiveness of those actions. KPIs to consider: % suppliers screened, % audited (announced + unannounced), grievance channel uptake, modern slavery training completion, remediation cases.
- Who's responsible
- Head of ESG + Internal Audit
- Frequency
- Annual
- Penalty
- As above.
- Source
- Regulator-direct link
- 7
Modern Slavery Act 2018 (Cth), s 16(1)(f) — Mandatory criterion 6
Describe the process of consultation with any entities the reporting entity owns or controls. For joint statements (s 14), the consultation process must be described for each consulted entity.
- Who's responsible
- Company Secretary
- Frequency
- Annual
- Penalty
- As above.
- Source
- Regulator-direct link
- 8
Modern Slavery Act 2018 (Cth), s 16(1)(g) — Mandatory criterion 7
Any other relevant information — COVID-19 impact, Ukraine/Russia conflict, climate-related disclosures with modern slavery dimensions, indigenous community engagement, Uyghur cotton or polysilicon exposure (Xinjiang).
- Who's responsible
- Head of ESG
- Frequency
- Annual
- Penalty
- As above.
- Source
- Regulator-direct link
- 9
Modern Slavery Act 2018 (Cth), s 13 (approval by principal governing body)
The principal governing body of the reporting entity (the board, for a company) must approve the statement before publication. Approval evidenced in board minutes.
- Who's responsible
- Board
- Frequency
- Annual
- Penalty
- Statement non-compliance; published on register without governing-body approval is invalid.
- Source
- Regulator-direct link
- 10
Modern Slavery Act 2018 (Cth), s 14 (joint statements)
Joint statements covering multiple entities are permitted but each entity must be identified, consulted, and the statement must address each entity's criteria.
- Who's responsible
- Company Secretary
- Frequency
- Annual (if applicable)
- Penalty
- Statement non-compliance.
- Source
- Regulator-direct link
- 11
Modern Slavery Act 2018 (Cth), s 13(1) — submission timeline
Submit the statement to the Modern Slavery Statements Register within 6 months of the end of the reporting period. For 30 June year-end entities, by 31 December.
- Who's responsible
- Company Secretary
- Frequency
- Annual — by 31 December (for 30 June year-end)
- Penalty
- Public listing on register without statement; civil penalty proposed.
- Source
- Regulator-direct link
- 12
Modern Slavery Act 2018 (Cth), s 19 (responsible Minister request)
If the Minister has reasonable grounds to believe a reporting entity has failed to comply, the Minister may request an explanation or remedial action. The Minister may publish the failure on the register.
- Who's responsible
- General Counsel + Company Secretary
- Frequency
- Event-driven
- Penalty
- Reputational; lead indicator for civil penalty reform.
- Source
- Regulator-direct link
- 13
Modern Slavery Act 2018 (NSW)
For NSW Government procurement: comply with NSW-specific reporting overseen by the NSW Anti-Slavery Commissioner. Most reporting obligations are harmonised with Cwlth MSA.
- Who's responsible
- Procurement + ESG
- Frequency
- Annual / procurement-cycle
- Penalty
- Loss of NSW Government procurement eligibility.
- Source
- Regulator-direct link
- 14
Procurement-led obligation (where applicable)
Embed modern slavery clauses in supplier contracts: right to audit, training requirement, code of conduct adherence, remediation co-operation, sub-contract flow-down.
- Who's responsible
- Procurement + Legal
- Frequency
- Ongoing — at supplier onboarding
- Penalty
- Statement non-compliance; reputational risk; potential breach of contract recourse.
- Source
- Regulator-direct link
Deadlines
Pulled from the Rules Mate compliance calendar. Click through for the full deadline page.
Forms and regulator portals
Direct links to the lodgement forms and regulator portals. Rules Mate does not host copies — we link to the official source.
Modern Slavery Statements Register — statement lodgement
Online portal for submitting Modern Slavery Statements. Requires entity registration, statement upload, contact details and governing-body approval evidence.
Open portal →Commonwealth Modern Slavery Act Guidance for Reporting Entities
Attorney-General's Department guidance — the authoritative reference for what each mandatory criterion requires.
Open portal →NSW Anti-Slavery Commissioner — supplier reporting (where applicable)
Separate NSW regime affecting NSW Government suppliers and NSW state-owned corporations.
Open portal →
Free tools that help
Interactive Rules Mate tools matched to this persona.
What changes 2025–2026
2024 — Anti-Slavery Commissioner appointed
The federal Anti-Slavery Commissioner role was operationalised in 2024 and has issued thematic reviews of garment, electronics and renewable-energy supply chain statements. Year-3+ statements are now benchmarked against the Commissioner's published expectations.
Modern Slavery Amendment Bill 2024 — civil penalties proposed
The bill (before Parliament as of 2026) proposes civil penalties for non-publication and false statements + a lowered $50M revenue threshold + harmonisation with NSW. Watch for assent; reporting entities should be statement-ready under the proposed regime.
Reporting period 1 July 2025 – 30 June 2026 — Statement due 31 December 2026
For 30 June year-end manufacturers, the FY26 statement is due 31 December 2026.
Reporting period 1 July 2026 – 30 June 2027 — Statement due 31 December 2027
The FY27 reporting period covers the first full year under the proposed reformed regime if passed.
2025-2026 — NSW Anti-Slavery Commissioner thematic reviews
Sector-specific reviews of construction, agriculture and electronics supply chains driving supplier-tier expectations upward.
In-depth reading
11 Rules Mate articles tagged to this playbook.
Modern Slavery Statement: when each entity's statement is due
Reporting entities under the Modern Slavery Act 2018 (Cth) must publish a statement within 6 months of their reporting period ending. Here's how the calendar works for the common year-ends.
Modern Slavery Act: Australia vs the UK compared
How Australia's Modern Slavery Act 2018 compares to the UK Modern Slavery Act 2015 — reporting thresholds, mandatory criteria, the central register, and penalties.
ASRS Group 1: what you must disclose in your first sustainability report
If you're Group 1 (FY commencing on/after 1 Jan 2025), your first AASB S2-aligned climate disclosures are due. Here's exactly what goes in.
Australian compliance calendar 2026–2027: every deadline you need
A month-by-month list of every major Australian compliance deadline for 2026 and 2027 — tax, super, AML, privacy, climate, WHS, modern slavery. Free .ics download.
ASRS vs ISSB vs CSRD: how Australia's climate disclosure compares
Australia's mandatory climate disclosure (ASRS / AASB S2) compared to the global ISSB baseline and the EU's CSRD — scope, phasing, assurance and what dual-listed entities need to know.
EU Carbon Border Adjustment Mechanism (CBAM): what it means for Australian exporters
The EU's CBAM puts a carbon price at the EU border on imports of cement, iron + steel, aluminium, fertiliser, electricity and hydrogen. Definitive period from 1 January 2026. Here's the impact on Australian exporters.
GEMS Act energy efficiency standards and labelling
The Greenhouse and Energy Minimum Standards Act 2012 sets energy efficiency standards and labelling for prescribed appliances. Here's what's covered and what suppliers must do.
The EPBC Act: matters of national environmental significance and 'controlled action' approvals
Projects likely to have a significant impact on matters of national environmental significance need approval under the Environment Protection and Biodiversity Conservation Act 1999. Here's the framework.
The UN Guiding Principles on Business and Human Rights: what Australian businesses need to know
The UN Guiding Principles (UNGPs) set out the corporate responsibility to respect human rights. They underpin Modern Slavery Act statements, ESG due diligence, and Australian Government procurement.
ACNC External Conduct Standards: rules for charities operating overseas
Registered charities that operate outside Australia must meet four External Conduct Standards under the ACNC Act 2012. Here's what each Standard requires.
The National Greenhouse and Energy Reporting Act 2007 (NGER): who reports and what
Corporations with significant emissions or energy use must report annually under the NGER Act. The reports feed the Safeguard Mechanism, ASRS climate disclosure, and the National Greenhouse Account.
Frequently asked
Our turnover sits at $95M — should we report voluntarily?
Voluntary reporting is permitted (s 6) and is encouraged by the Attorney-General's Department. The benefits are practice, supplier-engagement leverage, and procurement-cycle eligibility — many large customers now require statements from second-tier suppliers regardless of the $100M threshold.
Can a Tier-1 supplier audit reasonably cover Tier 3 risks?
No. The Anti-Slavery Commissioner's 2024 review explicitly criticised supply chain mapping that stops at Tier 1. Manufacturers in cotton, electronics, leather, mica, palm oil or bricks need to demonstrate active tracing into Tier 3 — typically through certified raw-material schemes (Better Cotton, RJC, RBA, MSI) or supplier-of-supplier audits.
Does the Modern Slavery Act cover wage theft and forced overtime in our domestic factories?
Yes. The definition of modern slavery covers forced labour, deceptive recruiting, debt bondage and trafficking — wage theft amounting to forced labour is captured. The Fair Work Act and modern slavery regime overlap: the same conduct can attract criminal Fair Work penalties and modern slavery statement disclosure.
What is the practical penalty for a non-compliant statement today?
Today: reputational (the register is public; the Attorney-General can list non-compliance). Proposed: civil penalty under the Modern Slavery Amendment Bill 2024. Procurement-cycle risk is the bigger practical pressure — Tier-1 buyers screen second-tier statements before contract renewal.
We acquired a foreign subsidiary mid-year. Are we still reporting?
Yes — the consolidated revenue test captures the controlled group. New subsidiaries should be added to the statement scope; the supply chain mapping must extend to their operations. Year-1 partial disclosure is acceptable; Year-2 full integration is expected.
How does this interact with Scope 3 climate disclosure under ASRS?
Both look at the supply chain. Scope 3 looks at emissions; modern slavery looks at people. The supplier-engagement infrastructure (questionnaires, audits, code of conduct) often serves both. Many manufacturers are building integrated supplier sustainability programs to handle both regimes.
What does NSW MSA add for a non-NSW-domiciled manufacturer?
If you supply NSW Government or are a NSW state-owned corporation, NSW MSA applies separately. If you have no NSW Government exposure and are not NSW-domiciled, the federal MSA is the sole regime — but the NSW Commissioner's thematic reviews influence federal expectations.
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