Modern Slavery Legislation

Canada Legislation:
Since July 2020, Canada's Customs Tariff Act has banned imports made using forced labour, in whole or part. In May 2023, Parliament passed the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211), in force since 1 January 2024. It requires certain companies and government bodies to file annual reports on steps taken to prevent forced and child labour in their supply chains. Non-compliance can bring fines of up to CAD 250,000.

The regime is being overhauled. On 12 June 2026, the government tabled Bill C-35, the Ban on Importing Goods Made with Forced Labour Act. It would replace the Customs Tariff ban with a standalone law, let the government list high-risk goods by producer or region, and require importers to prove those goods weren't made with forced labour or have them turned away. The CBSA would also get stronger powers to detain and inspect shipments.

United States Legislation:
California’s Transparency in Supply Chains Act 2010 applies to companies with annual gross revenues of USD 100 million or more. These organisations are required to publicly disclose the measures they take to address human trafficking and forced labour within their direct supply chains.

Under the U.S. Tariff Act of 1930, Customs and Border Protection has long held the authority to issue Withhold Release Orders. These orders allow goods to be detained where there is reasonable suspicion they were produced using forced or indentured labour.

More recently, the Uyghur Forced Labour Prevention Act of 2021 introduced a rebuttable presumption relating to goods originating from China’s Xinjiang region. In practice, this means such goods are assumed to be produced using forced labour. As a result, they are prohibited from entering the United States unless companies can provide clear and convincing evidence to the contrary.

United Kingdom Legislation:

The UK’s Modern Slavery Act 2015 consolidates legislation relating to slavery and human trafficking and provides courts with powers such as issuing prevention and risk orders, confiscating assets, and supporting victims. It also established the role of the Independent Anti-Slavery Commissioner to promote best practice in the prevention and detection of modern slavery.

In addition, the Act requires organisations with an annual turnover exceeding £36 million to publish an annual statement outlining the actions they are taking to address modern slavery risks within their operations and supply chains. Although this reporting obligation is not currently subject to legal enforcement, a 2019 independent review recommended strengthening the regime by aligning it more closely with Australia’s more robust and enforceable framework.

Australian Legislation:
Australia's Modern Slavery Act 2018 applies to organisations with consolidated annual revenue of at least AUD 100 million. It requires them to report on modern slavery risks in their operations and supply chains. Statements must explain how risks are identified, assessed, and addressed. They're submitted annually to a public register administered by the Attorney-General's Department. Since December 2024, Australia's first Anti-Slavery Commissioner, Chris Evans, has also had oversight functions under the Act.

The Act has not, until now, included financial penalties for non-compliance. That's changing. On 16 July 2026, the government announced a new criminal offence for companies with revenue over AUD 100 million that "fail to prevent" modern slavery in their supply chains, with a defence available if a company shows it took "reasonable steps." Civil penalties are also planned for failing to report or providing false information.

New Zealand Legislation:
In April 2022, New Zealand released draft legislation aimed at strengthening its response to modern slavery and worker exploitation. The proposal would require organisations to take active steps to address modern slavery risks across both domestic and international supply chains.

Under the draft framework, medium and large organisations would be required to publicly disclose the actions they have taken to prevent modern slavery. Larger entities would also be expected to go further. This includes conducting due diligence to identify, assess, and mitigate related risks.

European Legislation:

In 2024, the European Parliament introduced the Forced Labour Regulation (FLR), which gives the European Union the power to prohibit the sale, import, and export of goods made using forced labour. Under the regulation, products found to be linked to forced labour must be withdrawn from the EU market.

Failure to comply with the FLR can lead to enforcement actions, including financial penalties, sanctions, and exclusion from public procurement opportunities.

France Legislation:

Under France’s Corporate Duty of Vigilance Law of 2017, large companies with more than 5,000 employees are required to develop and publicly disclose a vigilance plan. This plan must outline how the organisation identifies, prevents, and mitigates risks to human rights and environmental standards across its own operations and throughout its supply chains.

Failure to meet these obligations can result in legal action and the imposition of financial penalties in France, reinforcing the expectation that businesses take active responsibility for managing and addressing these risks.

Germany Legislation:

Germany’s Supply Chain Due Diligence Act was passed in 2021 and came into force in 2023. It requires companies with more than 3,000 employees to identify, prevent, and report on human rights and environmental risks across their own operations and supply chains. This includes risks related to forced and child labour.

From 2024, the scope of the law expands to cover companies with 1,000 or more employees. Failure to comply with these obligations can result in substantial financial penalties. Companies may also face exclusion from public procurement processes in Germany.

Norway Legislation:

Norway’s Transparency Act, which came into effect in July 2022, requires companies with 50 or more employees to conduct annual human rights due diligence across their operations and supply chains. Organisations must also publish reports outlining how they identify and address human rights risks.

A key feature of the legislation is the right of individuals to request information from companies about their human rights impacts and the measures in place to manage and mitigate those risks in Norway.