TISC: What the updated Modern Slavery Act guidance means for your business
14 July
In March 2025, The Home Office published updated guidance for Transparency in Supply Chains (TISC) reporting under the Modern Slavery Act 2015.
For the estimated tens of thousands of UK businesses with a global annual turnover above £36 million, the guidance sets out clearer expectations than before – and some of them represent a significant shift in what good reporting looks like. Three changes in particular deserve attention.
You need to show a comprehensive approach to due diligence and stakeholder engagement
The guidance is now more clearly aligned with international frameworks including the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. It more clearly lays out expectations that the company reports on its own business model as well as how risks are managed along its supply chain and asks for more granular evidence of supply chain engagement.
The guidance also emphasises a need for organisations to look at their procurement practices, payment terms, delivery timelines, and cost pressures – asking honestly whether these create vulnerabilities further down the chain. Pricing pressure, tight delivery windows, and short-term contract structures have all been linked to labour exploitation in global supply chains. The guidance now asks businesses to make that connection explicit.
Both Level 1 and 2 guidance also now cover stakeholder engagement – a central tenet of the UNGPs. The guidance asks for evidence at each stage of the due diligence cycle of how internal teams and external stakeholders, including workers, farmers, suppliers, civil society, government and trade unions are consulted and collaborated with.
For organisations that have treated modern slavery reporting as a compliance exercise separate from commercial decision-making, this requirement signals a change of direction.
You now have to say what you don’t know
Modern slavery statements have long asked companies to describe their supply chains and the steps they are taking to address risk. The updated guidance goes further. Organisations must now explicitly acknowledge gaps in their supply chain knowledge, rather than simply reporting on what they have visibility of.
This is a more honest starting point than most current statements reflect. The guidance structures reporting around six areas, including organisational structure and supply chains, due diligence, and risk assessment and management. Across all of them, the expectation is transparency about the limits of current knowledge alongside plans to address those limits.
The Level 2 requirements push this further still. Organisations working toward enhanced disclosure are expected to map worker recruitment pathways, migrant worker routes, and the role of labour intermediaries throughout their supply chains. For most businesses, this represents a significant step beyond current practice – and begins to close the gap between what statements say and what is really happening on the ground.
Remediation means reporting on what didn’t work too
The updated guidance requires organisations to report on remediation efforts including where the results have not been positive. Statements have typically skewed toward success narratives – steps taken, improvements made, commitments met. The guidance is now asking for something more candid.
Documenting unsuccessful remediation is valuable precisely because it is difficult. It demonstrates that an organisation is conducting real due diligence rather than surface-level assurance, and it creates the kind of learning record that allows practice to improve over time. Level 2 organisations are expected to show how they have adapted their approach in response to setbacks – a standard that will require more rigorous internal evaluation than most current reporting processes allow for.
What this means for your business
The guidance is clear that it applies to organisations at different stages of this work. New reporters are encouraged to focus on foundational Level 1 disclosures; more experienced organisations are expected to work toward Level 2. The six reporting areas – organisational structure and supply chains, policies, due diligence, risk assessment and management, training, and effectiveness and monitoring – provide a structured framework for that progression.
What the guidance does not do is make this easy. Mapping labour intermediaries, assessing business model risk, and reporting honestly on remediation failures all require time, resource, and in many cases external expertise. The organisations that begin this work early will be better placed as scrutiny increases – from regulators, investors, and civil society alike.
