Who must comply with NSW Modern Slavery Act reporting (NSW public entities and their suppliers)?

Covered NSW public entities must take reasonable steps on modern slavery risk and report annually; their suppliers are drawn in through tender and contract clauses.

The Modern Slavery Act 2018 (NSW) and related legislation impose modern slavery due diligence and reporting obligations on more than 400 NSW public entities, with the legal obligations taking effect from 1 July 2022. The NSW Anti-slavery Commissioner, whose role the Act created, has issued a Shared Implementation Framework built around the Guidance on Reasonable Steps to Manage Modern Slavery Risks in Operations and Supply-Chains (GRS), formally in effect from 1 January 2024, together with an Inherent Risk Identification Tool, model tender and contract clauses and a public register. Where the NSW Procurement Board directs an entity to conform to the GRS, the direction has the force of law. Businesses that supply NSW government bodies meet these obligations through tender questions, contract clauses and due diligence requests passed down the supply chain.

Applies only if you supply NSW government agencies. Whether it applies turns on a fact that no industry, structure or size settles on its own.

How the regulator frames it: Covered NSW public entities, including agencies within the NSW Procurement Policy Framework, local councils, certain NSW universities and Local Aboriginal Land Councils (the Commissioner publishes the list of covered entities). Their suppliers are drawn in contractually through GRS model tender and contract clauses.

What triggers it: Being a covered NSW public entity that procures goods and services; for suppliers, tendering for or holding a NSW public sector contract that includes modern slavery clauses.

Jurisdiction: New South Wales law only. A business with no operations in NSW is outside it, whatever the rest of the test says.

Outcome across the 35 industries Rules Mate maps (35 of 35: no).

The answer is the same in every industry: no. Industry does not change who must comply.

Structure does not change the answer across all industries: for every structure the answer is "no".

Size does not change the answer across all industries: at every size band the answer is "no".

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 6–19 employees, turnover $1M–$3M: does not apply. Requires a trigger outside this questionnaire.

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

• The business supplies government customers: it becomes worth checking, because it applies only if you supply NSW government agencies.

The engine shows this obligation as "check whether this applies" when a business has operations in NSW and government customers. It then applies only if you supply NSW government agencies. That fact is not something Rules Mate can infer from industry, structure or size.

When due

Annually: modern slavery information is included in the entity's formal annual report (timing set by its governing legislation) and the online GRS Annual Reporting Form is submitted when that report is published. Inherent Risk Identification Tool version 2.0 applies from 1 July 2025 (financial-year reporters) or 1 January 2026 (calendar-year reporters).

Frequency

Annual

Evidence to keep

Annual report modern slavery disclosures (using the Appendix K template); submitted GRS Annual Reporting Form; category-level risk mapping with the Inherent Risk Identification Tool and supplier-level due diligence; tender and contract clauses (heightened or streamlined); heightened modern slavery due diligence reports where required; remediation records.

Status

Current

Priority

Medium

Maximum penalty: No pecuniary penalty for covered public entities is stated in the Commissioner's guidance; compliance is overseen by the Anti-slavery Commissioner, and a NSW Procurement Board direction to conform to the GRS has the force of law. Supplier obligations arise from the modern slavery clauses in each NSW government contract.

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

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 medium priority, and is a annual obligation.

Regulated by NSW Anti-Slavery Commissioner.

NSW Anti-Slavery Commissioner: First state-level Anti-Slavery Commissioner — NSW Modern Slavery Act 2018.

• NSW Anti-Slavery Commissioner

Free tools that help with this obligation:

• Modern Slavery threshold
• Modern Slavery statement scaffold
• Climate reporting tier