Who must comply with Modern Slavery Statement (Cwlth)?
The applicability test for Modern Slavery Statement (Cwlth) (ASIC), 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 a Modern Slavery Statement annually.
Modern Slavery Act 2018 (Cwlth) requires reporting entities (≥$100M consolidated revenue) to publish a Modern Slavery Statement addressing 7 mandatory criteria within 6 months of year-end. From 2024 reforms — Anti-Slavery Commissioner appointed; possible NSW + civil penalties for non-publication. Joint statements permitted.
The applicability test
Applies when the business has consolidated revenue ≥ $100M.
How the regulator frames it: Entities with ≥$100M consolidated revenue + Commonwealth (mandatory regardless of revenue).
What triggers it: Annual financial year close.
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 financial year end.
- Frequency
- Annual
- Evidence to keep
- Published statement addressing 7 mandatory criteria, signed by principal governing body.
- Status
- Current
- Priority
- High
Penalty for not complying
No maximum penalty is recorded for this obligation in the Rules Mate corpus; check the regulator source below.
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.
Dates in the compliance calendar
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 Australian Securities and Investments Commission.
ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).
Free tools that help with this obligation:
Questions
- Who must comply with Modern Slavery Statement (Cwlth)?
- Applies when the business has consolidated revenue ≥ $100M.
- Does Modern Slavery Statement (Cwlth) apply to sole traders?
- 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.
- Does Modern Slavery Statement (Cwlth) apply to businesses with 1–5 employees?
- No (1–5 employees, turnover $100K–$1M).
- When is "Modern Slavery Statement (Cwlth)" due?
- Within 6 months of financial year end.
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.