Australia’s Modern Slavery Act 2018 requires entities with annual consolidated revenue of $100 million or more to report annually on modern slavery risks in their operations and supply chains. Thousands of statements have now been published on the government’s public register. So what have we learned?

I’ve spent the past month reading through a cross-section of modern slavery statements from ASX-listed companies, government entities, and large private enterprises. The picture is mixed.

What companies are reporting

Most modern slavery statements follow a predictable structure. They describe the organisation, map their supply chains at a high level, identify potential risk areas (usually in offshore manufacturing, cleaning, security, and agriculture), describe their due diligence processes, and outline their plans for improvement.

The better statements include specific actions taken, measurable progress indicators, and honest assessments of where gaps remain. They identify particular supply chain tiers where visibility is limited and describe concrete steps to improve transparency.

The weaker statements — and there are many — read like boilerplate compliance documents. They describe policies that exist on paper, training programs that may or may not be effective, and risk assessments that are so generic they could apply to any company in any industry. “We recognise modern slavery is a risk in our supply chain and we are committed to addressing it” is not a meaningful disclosure. It’s a sentence.

The tiering problem

One of the most significant findings from reading these statements is that most companies have very limited visibility beyond their Tier 1 suppliers — the entities they contract with directly. Once you move to Tier 2 (the suppliers’ suppliers) and beyond, transparency drops dramatically.

This matters because modern slavery risk often concentrates in the lower tiers of supply chains, where labour conditions are hardest to monitor and regulatory oversight is weakest. A company might have robust procurement policies for its direct suppliers while having no idea what’s happening three or four links down the chain.

Some companies acknowledge this gap honestly. Others gloss over it with vague references to “ongoing supply chain mapping” without explaining what that actually involves or when they expect to have meaningful visibility.

Industry variation

The quality of reporting varies significantly by industry. Mining and resources companies tend to produce more detailed statements, partly because the sector has longer experience with supply chain due diligence through conflict minerals regulations and similar frameworks.

Financial services companies often produce comprehensive statements about their direct operations but struggle with the concept of supply chain risk in a services context. Their modern slavery risks are more likely to sit in their investment portfolios and lending decisions than in their office supply procurement.

Retail and consumer goods companies face perhaps the most complex challenge, with supply chains that span dozens of countries and thousands of suppliers. The best ones — like Woolworths and Coles — have invested significantly in supply chain mapping and monitoring. But even they acknowledge major gaps in visibility.

The enforcement question

The most significant criticism of Australia’s modern slavery reporting regime is the lack of enforcement. The Act doesn’t include penalties for non-compliance or for submitting a statement that’s inadequate. The government’s approach has been “name and encourage” rather than “regulate and penalise.”

This has produced predictable results. While some companies have treated the requirement as a catalyst for genuine supply chain improvement, others have treated it as a minimum-effort compliance exercise. Without consequences for poor reporting, there’s limited incentive to go beyond the bare minimum.

The statutory review of the Act recommended strengthening compliance mechanisms, including the introduction of penalties. Whether the government acts on those recommendations remains to be seen.

What good looks like

Among the statements I reviewed, several stood out for their quality and honesty.

The best statements describe specific, concrete actions rather than general commitments. They report on outcomes, not just processes. They acknowledge where their approach has limitations. They include worker voice — evidence that they’ve engaged with workers in their supply chain, not just managers.

They also demonstrate year-on-year progress. A first-year statement that identifies gaps is fine. A third-year statement that identifies the same gaps with no progress is not.

The broader picture

Modern slavery reporting is part of a broader trend toward mandatory corporate transparency on human rights and environmental issues. The EU’s Corporate Sustainability Due Diligence Directive, similar legislation in the UK and Germany, and Australia’s own expanding ESG reporting requirements all point in the same direction.

Companies that invest in genuine supply chain transparency now will be better positioned as these requirements expand. Those that treat modern slavery reporting as a compliance tick will find themselves scrambling when the bar inevitably rises. AI-powered supply chain mapping tools are starting to help, and firms like Team400’s AI agency in Sydney are working with mid-market companies to build automated supplier monitoring systems.

What needs to change

Three things would significantly improve the modern slavery reporting regime in Australia.

First, introduce meaningful penalties for non-compliance and for demonstrably inadequate statements. The current approach relies too heavily on goodwill.

Second, require companies to report on outcomes, not just processes. The question isn’t whether a company has a modern slavery policy. It’s whether that policy is actually identifying and addressing modern slavery risks.

Third, fund the regulator adequately. The Anti-Slavery Commissioner’s office needs resources to review statements, provide guidance, and hold companies accountable. Good regulation requires good resourcing.

Modern slavery is one of the most serious human rights issues in global supply chains. Australia’s reporting regime was a good start. Now it needs to mature into something with real teeth.