New TISC guidance: Raising the Bar for UK Modern Slavery Transparency

In March 2025, the Home Office updated its statutory guidance on Section 54 of the Modern Slavery Act 2015 – the Transparency in Supply Chains (TISC) provision. This applies to UK commercial organisations with a turnover of £36 million or more, requiring them to publish an annual modern slavery statement outlining the steps they took in the last financial year to manage modern slavery risks in their own operations and supply chains. 

In practice, expectations extend beyond those who are legally required to report. Major organisations such as Balfour Beatty now ask their supply chain partners to provide modern slavery statements as part of wider risk management processes, even if those suppliers fall below the legal threshold.    

The updated guidance clarifies what good and best practice looks like in a modern slavery statement and offers practical advice to help businesses move towards meaningful action, with an emphasis on transparency, accountability and continuous improvement.   

While adopting the new guidance remains voluntary, it’s already shaping behaviour: procurement teams and large organisations are beginning to ask high-risk suppliers which disclosure ‘levels’ they align with. For suppliers and subcontractors, especially those bidding into large supply chains, understanding and being able to evidence their position is becoming increasingly important.   

What’s in the TISC guidance

The guidance includes:

• A list of what information an organisation can include in a modern slavery statement to achieve ‘good’ and ‘best’ practice in each of the following headings: 

– Organisational structure, its business and its supply chain  

– Policies – including internal operating policies, international standards, stakeholder engagement and how the policies are communicated and implemented. 

– Risk assessment and risk management – including governance, frequency, risk assessment methodology and the role of stakeholders in identifying, understanding and prioritising current and future risks 

– Due diligence – including prevention and mitigation, supplier and worker engagement, grievance mechanisms supporting workers to report concerns and access remedy, remediation and incidents of modern slavery. 

– Training – including who is trained (internal and external stakeholders), how often, materials used and use of stakeholders to develop the content. 

– Monitoring and evaluation – including goal setting, KPIs, governance, use of data, evidencing outcomes, stakeholder engagement and continuous improvement.  

• The business case: Why tackling modern slavery and being transparent about the working conditions in supply chains is important, including case studies from investors, insurers and businesses.   

• Insights on key international frameworks to support tackling and reporting modern slavery – notably the UN Guiding Principles for Business and Human Rights (UNGPs) and the OECD Due Diligence Guide for Responsible Business Conduct. The UNGPs set out how businesses should conduct human rights due diligence by, ‘assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses and communicating how impacts are addressed’   

• The critical role of stakeholder engagement and collaboration. Critically this includes external stakeholder engagement e.g. workers in the supply chain, competitors, trade unions and those with lived experience.  

• A clear explanation of the Section 54 requirements: what they are, who they apply to, how to comply and when to report  

Changing the narrative

The guidance challenges myths that can hinder due diligence, stressing that modern slavery risks exist everywhere and no organisation is exempt. It includes clear statements such as:    

‘Modern slavery is so prevalent that if businesses are not identifying risks and cases, they are probably not looking hard enough’  

‘Those that do not enquire about or deny the presence of modern slavery risks in their supply chains are highly unlikely to have conducted effective risk assessment and due diligence’  

‘Responsible organisations are those that acknowledge the risks, take active steps to identify and mitigate the risks, remediate harms and can demonstrate publicly that they are tracking progress and continually improving’ 

Two levels of disclosure – ‘good’ and ‘best’ practice 

The guidance introduces a two-tiered approach to disclosures: Level 1 – ‘good practice’ and Level 2 – ‘best practice, for organisations with more experience of advanced risk management.   

Example: Assessing and managing risk 

• Level 1 (good) – Includes disclosure of when the risk assessments were done, date of next update, methods used (e.g. audits, worker engagement), highest priority risk to workers and supply chains and evidence of stakeholder engagement to identify and prioritise risks (e.g. with workers, local communities, buying teams).

• Level 2 (best practice) adds disclosure of the full risk register reviewed by the board, analysis of leverage to address risks, continuous direct worker engagement, improvements in supplier partnerships and purchasing practices, and identification of weaknesses with outcome-focused improvement targets.    

Staying ahead of the regulatory curve 

While the new TISC guidance is a significant step for UK businesses, it sits within a wider global shift towards tougher regulation and enforcement on forced labour. It aligns UK due diligence efforts with leading international standards such as the UNGPs and OECD Guidelines and will better equip organisations for upcoming regulations reshaping supply chains – including the EU Forced Labour Regulation and the Corporate Sustainability Due Diligence Directive (CSDDD). At the same time, sanctions and import restrictions linked to forced labour are intensifying worldwide.    

In July 2025, the UK Parliament’s Joint Committee on Human Rights published, ‘Forced Labour in the UK’s Supply Chains’, concluding that the UK is at risk of falling behind international peers like the EU and US in addressing forced labour. Its recommendations include the introduction of mandatory human rights due diligence legislation, an import ban on goods connected to forced labour and tougher penalties.  

The direction of travel is clear: businesses that align with the TISC guidance will be much better prepared for what’s coming next. And let’s face it, the shift is driven not just by law, but by ESG expectations from investors like CCLA Investment, customers and wider society. Increasingly , reputation and resilience will be defined by how seriously businesses act, not just by what the law requires.  

Need help strengthening your modern slavery and human rights due diligence, or understanding how your current approach aligns with best-practice frameworks? Book a free discovery call with our Modern Slavery Expert.