Who must publish an annual Modern Slavery Statement?
The applicability test for Publish an annual Modern Slavery Statement (Anti-Slavery Commissioner), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Some businesses
Applies when the business has consolidated revenue ≥ $100M.
What the obligation is
Entities with consolidated revenue ≥$100M must publish an annual Modern Slavery Statement.
The Modern Slavery Act 2018 (Cth) requires reporting entities with consolidated revenue of at least $100M to publish a Modern Slavery Statement within 6 months of the end of their reporting period. Mandatory criteria cover entity structure, supply chains, risks, actions to address risks, effectiveness, consultation, and other relevant information. Statements are lodged on the Modern Slavery Statements Register. The Anti-Slavery Commissioner (federal) monitors compliance.
The applicability test
Applies when the business has consolidated revenue ≥ $100M.
How the regulator frames it: Australian entities and entities carrying on business in Australia with annual consolidated revenue ≥AUD 100M.
What triggers it: Consolidated revenue threshold met in a reporting period.
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (35 of 35: depends on size or structure).
The answer is the same in every industry: depends on size or structure. Industry does not change who must comply.
Business structure and size
Structure does not change the answer across all industries: for every structure the answer is "depends on size or structure".
| Size band | Answer across all industries, any structure |
|---|---|
| No employees (turnover $100K–$1M) | No |
| 1–5 employees (turnover $100K–$1M) | No |
| 6–19 employees (turnover $1M–$3M) | No |
| 20–99 employees (turnover $3M–$10M) | No |
| 100–499 employees (turnover $10M–$100M) | No |
| 500+ employees (turnover $100M–$1B) | Yes |
Worked examples
Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:
- Pty Ltd company in real estate agents with 500+ employees, turnover $100M–$1B: applies. Consolidated revenue ≥ $100M.
- Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires consolidated revenue ≥ $100M.
- Pty Ltd company in real estate agents with no employees, turnover $100K–$1M: does not apply. Requires consolidated revenue ≥ $100M.
What you must do, and when
- When due
- Within 6 months of end of reporting period.
- Frequency
- Annual
- Evidence to keep
- Modern Slavery Statement approved by the principal governing body, signed by a responsible member, lodged on the public register.
- Status
- Current
- Priority
- High
Penalty for not complying
Maximum penalty: No civil penalty under the Act today: the Minister can request an explanation or remedial action and publish details if the request is not complied with (s 16A). On 15 July 2026 the Government announced it will introduce civil penalties for reporting non-compliance and proposed a criminal 'failure to prevent' offence; no bill had been introduced as at 3 October 2026 (Parliament of Australia bills register).
Audit or assurance level
Self-assessment. Authority: Modern Slavery Act 2018 (Cth) ss5, 13, 16; Attorney-General's Department 'Modern Slavery Act'.
Frequency: Annually, within 6 months after the end of the reporting period.
Who can perform it: Approved by the principal governing body and signed by a responsible member. No independent audit or assurance is required.
Enforcement examples
- Anti-Slavery Commissioner public list of non-compliant reporting entities (2024): Reporting timelines are public — late or non-existent statements are easily benchmarkable by procurement, customers and investors.
- Anti-Slavery Commissioner non-compliance lists 2024 (2024): Late + missing statements publicly benchmarkable; procurement + investor risk exposure.
Obligations with the same applicability test
If this obligation applies to you, so does this one: the engine uses the same rule for each.
What usually applies alongside it
Across the 1,890 business profiles Rules Mate evaluates, these obligations apply to most of the businesses this one applies to, and are far more common among them than among businesses generally:
- Lodge Payment Times Reports (large business): applies to 100% of the same businesses (6.0× the overall rate)
- Pay ACT payroll tax when threshold met: applies to 100% of the same businesses (3.0× the overall rate)
- Pay NSW payroll tax when threshold met: applies to 100% of the same businesses (3.0× the overall rate)
- Pay Northern Territory payroll tax when threshold met: applies to 100% of the same businesses (3.0× the overall rate)
- Pay Queensland payroll tax when threshold met: applies to 100% of the same businesses (3.0× the overall rate)
Where it sits in the corpus
Rules Mate tracks 3 published obligations tagged "modern slavery", 0 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated high priority, and is a annual obligation.
Regulator, legislation and tools
Regulated by Office of the Anti-Slavery Commissioner (Commonwealth).
Anti-Slavery Commissioner: Independent statutory office monitoring modern slavery reporting under the Modern Slavery Act 2018 (Cth). Reporting threshold remains AUD 100M.
Modern Slavery Act 2018: Requires entities with consolidated annual revenue ≥AUD 100M to publish a Modern Slavery Statement on the public register within 6 months of reporting period end.
Free tools that help with this obligation:
Questions
- Who must publish an annual Modern Slavery Statement?
- Applies when the business has consolidated revenue ≥ $100M.
- Do sole traders need to publish an annual Modern Slavery Statement?
- Depends on size or structure. Across every industry and every size band, the engine's answer for a sole trader is: depends on size or structure.
- Do businesses with 1–5 employees need to publish an annual Modern Slavery Statement?
- No (1–5 employees, turnover $100K–$1M).
- When is "Publish an annual Modern Slavery Statement" due?
- Within 6 months of end of reporting period.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.