Modern Slavery Statement (Section 54) Readiness
Check the £36 million threshold, describe only steps you actually took and publish the board-approved, signed statement each year.
In Short
- Threshold: £36m total turnover.
- Board approves, director signs.
- Link it from your homepage.
Section 54 of the Modern Slavery Act 2015 requires commercial organisations that supply goods or services and meet a turnover threshold to prepare a slavery and human trafficking statement for each financial year. The threshold is £36 million under the 2015 transparency regulations. This guide covers who is in scope, what a statement contains, approval and publication. It reflects section 54 as revised on legislation.gov.uk, with amendments not yet in force noted there. Orientation, not legal advice. Sources checked 4 Oct 2026.
Who has to publish a statement
Section 54(2) covers a commercial organisation that supplies goods or services and has total turnover of at least the prescribed amount. Regulation 2 of the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 sets that amount at £36 million.
Is the organisation in scope?
| Test | Source |
|---|---|
| Body corporate or partnership | s.54(12) |
| Carries on business in any part of the UK | s.54(12) |
| Supplies goods or services | s.54(2)(a) |
| Total turnover £36m or more, incl. subsidiaries | s.54(2)(b); SI 2015/1833 regs 2-3 |
- Body corporate or partnership
- Source
- s.54(12)
- Carries on business in any part of the UK
- Source
- s.54(12)
- Supplies goods or services
- Source
- s.54(2)(a)
- Total turnover £36m or more, incl. subsidiaries
- Source
- s.54(2)(b); SI 2015/1833 regs 2-3
More on who has to publish a statement
Regulation 3 counts the turnover of the organisation and its subsidiary undertakings, after trade discounts, VAT and other turnover-based taxes. Section 54(12) defines a commercial organisation as a body corporate or partnership, wherever incorporated or formed, that carries on a business or part of a business in any part of the United Kingdom.
What the statement must and may say
Section 54(4) requires either a statement of the steps taken during the financial year to ensure slavery and human trafficking is not taking place in any supply chain or any part of the business, or a statement that no such steps were taken. Section 54(5) lists what it may include: structure, business and supply chains; policies; due diligence processes; the parts of the business and supply chains at risk and how that risk is assessed and managed; effectiveness measured against chosen indicators; and training available to staff.
More on what the statement must and may say
The list is permissive, not a mandatory template.
Approval and Signature
Section 54(6) sets who approves and signs. For a body corporate other than an LLP, the board of directors or equivalent management body approves it and a director or equivalent signs.
Worked Example: FY2026 Statement MS-26
- Year endSupplier risk review and audit actions summarised
- +2 monthsDraft states steps actually taken during the year
- +3 monthsBoard approves; director signs
- Same weekPublished with homepage link
More on approval and Signature
For an LLP the members approve and a designated member signs. For a limited partnership a general partner signs, and for other partnerships a partner signs. Keep board minutes, the approved version and the signed copy together so you can show who approved what and when. The software you use does not approve the statement; your board does.
Publishing on your website
Section 54(7) requires an organisation with a website to publish the statement there and to put a link to it in a prominent place on the homepage. Without a website, section 54(8) requires a copy to be provided to anyone who asks in writing, within 30 days of receiving the request.
More on publishing on your website
Section 54(11) makes the duties enforceable by the Secretary of State through civil proceedings for an injunction, or specific performance in Scotland. Guidance issued under section 54(9) may say more about content; that guidance was not reviewed here.
Evidence Behind the Statement
A statement is only as useful as the evidence behind it. Typical supporting records include an approved supplier list with risk ratings by country and category, supplier questionnaires and declarations, audit reports and corrective actions, contract clauses, staff training records and grievance or whistleblowing logs.
More on evidence Behind the Statement
Recording these by supplier and date makes it easier to describe steps actually taken during the financial year. Decide who owns each record. Do not describe steps you did not take: section 54(4)(b) allows a statement that no steps were taken, and accuracy matters more than length.
Questions
What turnover triggers the duty?
£36 million total turnover, including subsidiary undertakings, under regulation 2 of the 2015 Transparency in Supply Chains Regulations, for organisations that supply goods or services and carry on business in the UK.
Who signs the statement?
For a company, the board approves it and a director signs (section 54(6)(a)). LLPs, limited partnerships and other partnerships have their own rules in section 54(6).
Where must it be published?
On the organisation's website, with a prominent link on the homepage (section 54(7)). Without a website, provide a copy within 30 days of a written request.
Must the statement follow a set format?
No. Section 54(5) lists topics the statement may include. Section 54(4) requires either the steps taken that year or a statement that no steps were taken.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
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