Modern Slavery Act 2018: who reports and what is due
If your group's consolidated revenue is $100 million or more and you carry on business in Australia, you owe an annual modern slavery statement. New penalties and a criminal offence were announced in July 2026, but they are proposals for now.
What is the Modern Slavery Act?
The Modern Slavery Act 2018 (Cth) requires entities with consolidated revenue of at least $100 million that are Australian or carry on business in Australia to publish an annual modern slavery statement. It must address seven mandatory criteria, be approved by the principal governing body and be lodged within six months of the reporting period's end.
Large Head Contractors And Developers
An entity is a reporting entity if its consolidated revenue is at least $100 million for the reporting period and it is an Australian entity or carries on business in Australia at any time in that period. Revenue is worked out across the entities it controls.
Commonwealth Bodies
The Commonwealth itself reports, as do corporate Commonwealth entities and Commonwealth companies with consolidated revenue of at least $100 million.
Smaller Entities That Volunteer
An entity below the threshold can volunteer by written notice before the reporting period ends. It then has the same reporting duties for that period, and it can only withdraw by notice given before a later period starts.
Trade Partners In The Chain
A trade partner (subcontractor) under the threshold has no duty of its own under the Act. Head contractors still have to describe risks across their supply chains, so they often send model clauses and questionnaires down the chain.
What the Modern Slavery Act asks for.
What you report, and when.
Modern Slavery Statement
To the Minister, through the online Modern Slavery Statements Register
Joint Statement
To the Minister, through the Register, covering each included entity
Explanation Or Remedial Action
To the Minister
- Consolidated Revenue Calculation
- Supply Chain Map And Risk Assessment
- Supply Chain Due Diligence Documentation
- Supplier Questionnaires And Contract Clauses
- Grievance And Remediation Records
- Consultation Records With Owned Or Controlled Entities
- Governing Body Approval And Signature
Testing Revenue One Company At A Time
The test is consolidated revenue, so controlled entities count together. A subsidiary below $100 million can still sit inside a group that has to report, and it needs to be covered by a statement.
Listing Policies But Not Effectiveness
Criterion 5 asks how you assess whether your actions work, separately from describing the actions. A statement full of policies with no measures leaves that criterion thin, and the department published fresh guidance on it in 2026.
Leaving Board Approval To The Last Week
The statement needs principal governing body approval and a responsible member's signature inside the six-month window. Board calendars rarely move, so work backwards from the meeting date, not the lodgement date.
How Catchment manages the Modern Slavery Act.
Modern Slavery Statement Builder
GovAssureThe builder holds your draft and prefills the action figures from your own records. When it is ready it publishes a PDF into the Document Register as a new revision, which you then lodge on the Modern Slavery Statements Register yourself.
Contract Clauses Tracked Per Package
GovAssureThe built-in framework adds Modern Slavery Contract Clause (C.C.22) as a document requirement. Set at package level, it reaches each new work package, and you switch it on for packages that already exist, so you can see which trade partners have filed it and which have not.
Due Diligence Evidence In One Place
GovAssureSupply Chain Due Diligence Documentation sits alongside the statement as its own requirement, and the Document Register can hold each revision of your own copy. That gives you the record to answer criteria 3 and 4 from.
Supplier Questionnaires As Surveys
GovAssureRun a modern slavery questionnaire as a Survey requirement, on a one-time or annual frequency, with responses coming back through each package. A reviewer accepts or sends back the package's Documents & Forms section, and only accepted responses show upstream.
Adopting this framework on a project generates these targets and documents. You can edit them to match your contract.
Modern Slavery Act questions.
Who has to report under the Modern Slavery Act?
Entities with consolidated revenue of at least $100 million for the reporting period that are Australian or carry on business in Australia. The Commonwealth and larger Commonwealth bodies also report, and smaller entities can volunteer.
When is a modern slavery statement due?
Within six months after the end of your reporting period, which is a financial year or your other annual accounting period. A 30 June year-end means 31 December, and a 31 December year-end means 30 June.
What are the penalties for not lodging a modern slavery statement?
Today the Minister can ask for an explanation or remedial action, giving at least 28 days, and can publish the entity's name and details if it does not comply. The government announced on 16 July 2026 that it intends to add civil penalties and enforcement powers, but those are not yet law.
What is the proposed failure to prevent modern slavery offence?
It would make corporations with consolidated revenue over $100 million criminally liable for modern slavery in their supply chains unless they took reasonable steps to prevent it. Consultation closed on 25 September 2026, and the paper says the measures are not yet law and may change. It floats delayed commencement of 12 to 18 months and penalty options such as 100,000 penalty units.
Is the reporting threshold dropping to $50 million?
The threshold is still $100 million. The 2023 statutory review recommended lowering it to $50 million, and the July 2026 consultation paper still describes the reporting threshold as $100 million.
Can a group lodge one statement for several companies?
Yes. A joint statement can cover one or more reporting entities, if it is prepared in consultation with each one. Approval comes from each entity's governing body or a higher entity that controls them, and at least one covered entity can approve it if that is impracticable.
Does the Act apply to a subcontractor below $100 million?
Not directly, unless the business volunteers or sits inside a group that reports. In practice larger customers may ask for contract clauses and questionnaires, because they must describe risks in their own supply chains. The Register publishes model clauses and a supplier questionnaire for this.
- Modern Slavery Act 2018 (Federal Register of Legislation)
- Modern Slavery Act (Attorney-General's Department)
- Resources (Modern Slavery Statements Register, Attorney-General's Department)
- Commonwealth Modern Slavery Act 2018: Guidance for Reporting Entities (Attorney-General's Department)
- Modern Slavery Statements Register (Attorney-General's Department)
- Strengthening Australia's response to modern slavery in supply chains (consultation paper) (Attorney-General's Department)
- Strengthening Australia's response to modern slavery in supply chains (Attorney-General's Department Consultation Hub)
Reviewed 4 November 2026. General information to help you plan reporting, not legal advice. Policies change, so check the current version with the policy owner before you rely on it.
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