Strengthening Transparency in Supply Chains in the Immigration and Asylum Bill

This brief aims to inform the current scrutiny of the Immigration and Asylum Bill (Bill 105) by the Public Bill Committee so that any amendments to section 54 of the Modern Slavery Act 2015 avoid unintended consequences for UK businesses and workers in their supply chains, while achieving the stated aim of increasing transparency and accountability for modern slavery in business supply chains. The full brief is available to download here.

Amending the Modern Slavery Act 2015

In 2015 the UK was seen as a global leader in addressing modern slavery in business supply chains when it introduced modern slavery reporting responsibilities for businesses under section 54 of the Modern Slavery Act. Also known as the Transparency in Supply Chains (TISC) provision, it requires commercial organisations operating in the UK with a turnover of £36 million or more to produce an annual statement setting out the steps taken to ensure that slavery and human trafficking are not taking place in its own operations and its supply chains, or state that the organisation has taken no such steps.

However, more than 10 years since its adoption, research has shown little impact of TISC on corporate transparency with companies largely submitting poor-quality statements or failing to publish statements in the first place. This has been attributed at least partially to weaknesses in the design of the TISC provision, namely encouraging rather than mandating the content of reporting and the lack of sanctions for non-compliance. The 2024 review led by a select committee in the House of Lords and the 2019 review commissioned by the Home Secretary identified these among other weaknesses and recommended legislative and non-legislative changes to TISC. In its responses to these reviews the government accepted the majority of those recommendations, but so far only non-legislative recommendations have been actioned. For example, in 2025 the Home Office updated the TISC's statutory guidance.

If passed, the Immigration and Asylum Bill  (hereafter the Bill) introduced by the government in the House of Commons on June 30th, 2026, will for the first time introduce substantial amendments to the Modern Slavery Act 2015 and its TISC provision.

The main amendments to TISC proposed in this Bill are:

• Introducing mandatory reporting content of the slavery and human trafficking statement in Schedule 4ZA (referred to in Article 44 and outlined in Schedule 5 of the Bill);
• Extending the requirement to produce statements to public authorities (clause 46);
• Introducing provisions to enable the Secretary of State to make regulations to impose a financial penalty that may not exceed the higher of £1m or 1% turnover to non-compliant entities (clause 49).

 
In a nutshell

Overall, these amendments are welcome as they address, to some extent, some of the main weaknesses of the current TISC provision and some of the recommendations outlined in the above-mentioned reviews such as mandating the reporting against the six areas which are currently recommended, extending the scope to public bodies, and, for the first time, providing powers to introduce financial penalties for non-compliance. However, some amendments as currently proposed (and the absence of others) raise concerns. As currently formulated, the amendments are likely to lead to more entities engaging with the duty by publishing their modern slavery statements, but the quality of the content of the statements is unlikely to significantly improve, thus questioning the potential of these amendments to substantially increase corporate transparency and accountability. Moreover, the proposed amendments do not go as far for the UK to catch up with arguably more effective legislation developed by some of the world's largest economies (and largest trading partners of the UK) such as the European Union (EU) and the US. Namely, mandatory human rights due diligence legislation and forced labour trade ban laws.

This is discussed further in the attached brief through nine points that cut across three key themes i) the unintended consequences of addressing supply chain transparency in immigration policy, ii) the inadequacy of some reporting amendments, and iii) the need for stronger accountability mechanisms beyond transparency reporting only.

Next steps for the Immigration and Asylum Bill

The Public Bill Committee is expected to report to the House of Commons by Tuesday, 3 November 2026. The Joint Committee on Human Rights (JCHR) is also holding a legislative inquiry to consider the implications of this Bill for human rights. The call for evidence is open until September 1st, 2026.

The Department of Business and Trade (DBT) has finalised its assessment of the UK's approach to Responsible Business Conduct as part of the UK's trade strategy and it now sits with the Ministers. The UK government's response to this review may lead to changes to the Bill or the development of secondary legislation so as to ensure policy coherence.

Download the full brief 
 

Author:

Dr Sofia Gonzalez De Aguinaga, Research Fellow in Business, ESG & Modern Slaver, Bingham Centre for the Rule of Law, BIICL