Modern Slavery Laws That Reach Indian Suppliers

Why these laws reach you when none of them is Indian

The mechanism is the same in every case and it is worth being precise about, because it determines what an Indian company is actually managing.

Each of these statutes places a duty on a buyer established in or trading into the enacting jurisdiction. None places a duty on a foreign supplier. An Indian exporter files nothing, registers nothing and cannot be prosecuted under any of them.

What happens instead is that the buyer, unable to discharge its own duty without information from its chain, passes the requirement down by contract. Supplier codes of conduct, audit rights, information covenants, warranties and indemnities are the transmission mechanism. The Indian supplier's obligation is owed to its customer, not to a foreign regulator.

The practical consequence is that your contract matters more than the statute. Two suppliers to the same UK buyer may face very different obligations depending on what each signed. Reading the supplier agreement tells you more about your exposure than reading the Modern Slavery Act does.

The United Kingdom: transparency now, penalties coming

What section 54 currently requires

The UK Modern Slavery Act 2015 requires a commercial organisation carrying on business in the United Kingdom with a total turnover of £36 million or more to publish an annual slavery and human trafficking statement setting out the steps taken to ensure that slavery and human trafficking are not taking place in its business or supply chains.

The Act's defining feature, and its most criticised one, is that the content is not mandatory. Section 54 suggests areas a statement may cover, including organisational structure and supply chains, policies, due diligence processes, risk assessment and management, effectiveness measured against performance indicators, and training. But an organisation may lawfully publish a statement saying it has taken no steps at all.

There is currently no financial penalty for a defective statement. Enforcement in practice has been reputational.

The reform now before Parliament

That is changing, and Indian suppliers to UK buyers should expect the change to reach them well before it becomes law.

Provisions inserted into the Immigration and Asylum Bill, introduced on 30 June 2026, would materially alter the regime:

• Statement content becomes mandatory under a new Schedule 4ZA, covering risk assessment, policies, due diligence, training and effectiveness.
• A financial penalty of up to 1 per cent of turnover or £1 million, whichever is higher, becomes available.
• Reporting is extended to public authorities.
• The £36 million threshold is unchanged.

Two qualifications matter, and both cut against reading the reform as more radical than it is. Schedule 4ZA mandates the topics a statement must contain, not the conduct behind them: an organisation may still state that it has no policies or has conducted no due diligence, provided it gives reasons. It is a sharper comply-or-explain regime, not a substantive duty. And the Bill confers a regulation-making power subject to that penalty cap rather than imposing the penalty directly.

The Bill passed its second reading on 13 July 2026 by 264 votes to 90 on the official division record, and went to committee, where the Public Bill Committee was due to sit from 10 September 2026 and to report by 3 November 2026. It is not law, and the current discretionary regime continues to apply until it is.

The commercial significance for Indian suppliers is not the penalty itself, which falls on the UK buyer. It is that a buyer facing mandatory content requirements and turnover-based fines will need substantive answers from its supply chain rather than the generic assurances that satisfied a discretionary regime.

Australia: reporting without pecuniary penalties, for now

The Australian Modern Slavery Act 2018 requires an entity with consolidated revenue of at least A$100 million for the reporting period to publish an annual modern slavery statement, where the entity is an Australian entity or carries on business in Australia at any time in that period. Two points of precision: the statute says at least, so an entity landing exactly on A$100 million is caught; and the measure is the reporting period, defined as a financial year or other annual accounting period applicable to the entity, with consolidated revenue worked out in accordance with the accounting standards even where those standards would not otherwise apply. The Commonwealth is a reporting entity irrespective of revenue.

It is more prescriptive than the UK Act in one respect and weaker in another.

More prescriptive: section 16(1) sets seven mandatory criteria for a statement, and section 18 requires the Minister to maintain the Modern Slavery Statements Register and to make it available for public inspection without charge on the internet. That makes comparison across reporting entities straightforward and has driven a visible improvement in statement quality.

Weaker, but not consequence-free, and this is where most summaries go wrong. The Act contains no offence and no civil penalty, and section 25(2)(a) expressly bars the rules from creating either. But section 16A gives the Minister, where reasonably satisfied that an entity has failed to comply, power to request a written explanation or specified remedial action within not less than 28 days, and under section 16A(4) to publish on the register the entity's identity, the request and the reasons. That is a statutory naming power, reviewable by the Administrative Review Tribunal. The accurate formulation is: no pecuniary penalty, with ministerial request and public naming as the sanction.

This position is on a short clock. On 16 July 2026 the Government announced that it will legislate a criminal failure to prevent modern slavery offence for entities above the A$100 million threshold, with a reasonable steps defence, together with civil penalties and enforcement powers for non-compliance with existing obligations. No such Bill had been enacted as at August 2026, and reporting indicated introduction was expected in 2027.

The threshold was reviewed and left alone. The McMillan statutory review, tabled 25 May 2023, made 30 recommendations including lowering the threshold to A$50 million. The Government responded on 2 December 2024, agreeing in full, in part or in principle to 25 of the 30, but noted rather than accepted the threshold recommendation and retained A$100 million, saying it would reconsider at the next review. The July 2026 reform package is built around the A$100 million cohort, so no lowering is proposed even now.

An Australian Anti-Slavery Commissioner has been established, by the Modern Slavery Amendment (Australian Anti-Slavery Commissioner) Act 2024, No. 42 of 2024, assented to 11 June 2024 and commenced 7 November 2024, inserting Part 3A. The first Commissioner commenced on 2 December 2024 for a five-year term. Note the limit: section 20C(2) provides that the Commissioner may not investigate or resolve individual complaints.

For an Indian supplier, Australian buyers tend to ask structured questions drawn from the mandatory criteria, which makes their requests more predictable than UK requests but no more legally forceful.

Germany: substantive duties, with the reporting limb in retreat

The German Supply Chain Due Diligence Act, the Lieferkettensorgfaltspflichtengesetz or LkSG, is different in kind from the UK and Australian statutes. It imposes substantive due diligence duties, not merely a duty to describe what you do.

It applies by headcount in Germany, phased in:

• From: 1 January 2023; Employees in Germany: 3,000 or more
• From: 1 January 2024; Employees in Germany: 1,000 or more

In-scope companies must conduct risk analysis, establish preventive measures, take remedial action, operate a complaints procedure, and document their work.

The reporting duty has been suspended, and is being abolished

This is the part that has changed, and it is easy to misread.

A government bill, following a cabinet decision of 3 September 2025 and carried in Bundesrat printed paper BR-Drs 422/25 of 5 September 2025, would abolish the annual report to the federal supervising office retroactively from the 2023 reporting period and confine fines to serious violations, amending sections 3, 10, 21, 22 and 26 of the Act. It had its first reading in the Bundestag on 16 January 2026 and stands referred to committee. It is not law: there has been no Bundestag vote, no Bundesrat passage and no publication in the Federal Law Gazette. It had its first Bundestag reading on 16 January 2026. It had not completed its passage when this article was prepared and is not yet law.

A larger change is now in train, and it will matter more than the reporting bill. Under a reform package of 2 July 2026 the Federal Government decided to transpose the CSDDD into German law on a one-for-one basis, and to narrow the LkSG's own scope from autumn 2026 to companies with at least 5,000 employees and net worldwide turnover above €1.5 billion. Those are the CSDDD thresholds. If carried through, the effect is not a trimming of the reporting duty but a reduction in who the Act reaches at all, taking most currently in-scope companies outside it. An Indian supplier currently fielding LkSG questionnaires from a mid-sized German buyer may find that buyer falls out of scope entirely. In practice, however, the duty is already dormant. The federal supervising office announced non-enforcement of the LkSG reporting duty during 2025, and the reporting form is reported to have been deactivated in the autumn of that year. A specific deactivation date of the autumn of 2025 circulates and could not be confirmed against the office's own announcement; it should be checked before being relied on.

The critical point for suppliers is what survives. The underlying due diligence and internal documentation obligations are unaffected. German buyers must still analyse risk, act on findings and document what they did. They simply no longer file an annual report about it. A supplier that reads "Germany has scrapped the LkSG" and expects the questionnaires to stop has misunderstood which limb was removed.

Canada: the newest, and easy to miss

Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force on 1 January 2024.

The scope test is more complicated than the two-of-three summary that circulates, and the summary understates it.

An organisation is an entity under section 2 if it is listed on a stock exchange in Canada, in which case no size threshold applies at all; or if it has a place of business in Canada, does business in Canada or has assets in Canada and, on its consolidated financial statements, meets at least two of three thresholds in either of its two most recent financial years: at least C$20 million in assets, at least C$40 million in revenue, or an average of at least 250 employees. The thresholds are global figures, not Canada-only.

Being an entity is still not sufficient. Section 9 adds an activity test: the reporting Part applies only to an entity producing, selling or distributing goods in Canada or elsewhere, importing goods into Canada, or controlling an entity that does either.

Reports are due annually on or before 31 May.

The structure means the Act catches a wider range of companies than a single revenue test would, including asset-heavy businesses with modest turnover, and, through the listing limb, small listed issuers with no size qualification whatever. Indian suppliers to Canadian buyers frequently discover the obligation only when the questionnaire arrives, because the Act attracted less attention internationally than the UK and Australian statutes.

A pending development. Bill C-35, the Ban on Importing Goods Made with Forced Labour Act, received first reading on 12 June 2026 and was still awaiting second reading debate as at August 2026, with no advance expected until Parliament returned from summer recess. It would create a standalone import prohibition with a Minister-maintained list of suspect goods, an importer information-production duty and border detention powers, and would remove the forced and child labour reference from Customs Tariff item 9897.00.00. It does not amend the reporting regime, which would continue in parallel. It is not law.

Norway: the low threshold nobody expects

The Norwegian Transparency Act, the Åpenhetsloven, is the one most likely to surprise an Indian exporter, because its thresholds are an order of magnitude below the others.

There are two routes into scope, and summaries usually give only the second.

First, an undertaking that is a public-interest entity under section 1-6 of the Accounting Act, which covers listed companies, banks, credit institutions and insurers, is a "larger enterprise" regardless of size.

Second, an undertaking is in scope if, on the balance sheet date, it exceeds at least two of three thresholds: sales revenue of NOK 70 million, balance sheet total of NOK 35 million, or an average of 50 full-time equivalents in the financial year. Note the test is exceeds, so exactly 50 full-time equivalents is outside it, not inside. Parent companies are assessed on a consolidated basis, and a threshold crossing takes effect only in the second of two consecutive financial years in which it occurs.

The thresholds are set by section 3 of the Transparency Act itself. They are not borrowed from the Accounting Act's definition of large enterprises, and section 3 was amended by the Act of 21 June 2024 no. 42 implementing the EU sustainability reporting directive, in force 1 November 2024, which changed the cross-reference and added the two-consecutive-years rule without altering the figures.

Fifty employees is not a multinational test. It captures ordinary mid-sized Norwegian businesses, which means an Indian supplier with a modest Norwegian customer should assume that customer is in scope.

The Act requires companies to carry out human rights due diligence across their operations and supply chains and to publish an annual account of that work by 30 June each year. The account must also be republished on material changes to the enterprise's risk assessments, made easily accessible on its website, and signed. It also confers a right to information: any member of the public may, on written request, seek information about how a company addresses actual and potential adverse impacts, subject to refusal grounds including insufficiently specific or manifestly unreasonable requests, personal data, and competitively sensitive business information, the last of which is unavailable where actual human rights violations are known. And the company must respond.

The Norwegian Consumer Authority issued substantially updated guidance in December 2025, the most significant revision since the Act came into force.

What these regimes have in common, and where they diverge

In common:

They all bind buyers rather than foreign suppliers. They all operate on annual cycles. They all require the buyer to know something about its supply chain that only the supply chain can tell it. And they all reach Indian companies through contract rather than regulation.

Where they diverge, and it matters:

• Dimension: Content; Divergence: UK content currently discretionary; Australia, Canada and Norway prescribe it
• Dimension: Duty type; Divergence: UK, Australia and Canada require disclosure; Germany and Norway require substantive due diligence
• Dimension: Penalties; Divergence: Australia has no pecuniary penalty but a ministerial naming power under s.16A, with a failure-to-prevent offence announced 16 July 2026 and not yet enacted; UK is adding turnover-based fines; Germany is narrowing fines to serious violations
• Dimension: Threshold; Divergence: Norway catches every public-interest entity regardless of size, and otherwise companies exceeding two of NOK 70m turnover, NOK 35m balance sheet and 50 full-time equivalents; Australia requires A$100 million revenue
• Dimension: Direction; Divergence: UK tightening; Germany loosening its reporting limb

That last row is the analytical point most worth carrying away. There is no single global trajectory for modern slavery regulation. A supplier serving UK, German and Norwegian customers is dealing with three regimes moving in different directions at the same time.

What an Indian supplier actually has to produce

Across all five regimes, buyer requests converge on a similar evidence set. Building it once serves all of them.

A supply chain map identifying your own suppliers and, for higher-risk inputs, the tiers behind them.

A documented risk assessment identifying where in your operations and chain forced labour, child labour or trafficking risk is most likely, with a stated basis for that judgement.

Policies and their evidence of operation: recruitment practices, prohibition of recruitment fees, age verification, freedom of movement and retention of identity documents, working hours and wage records.

Grievance and remediation records, showing that a channel exists, is accessible to workers including contract and migrant workers, and that complaints were actually handled.

Audit and corrective action history, including what was found and what changed as a result. Buyers increasingly discount audits with no findings.

Training records for relevant staff.

The recurring failure is producing policies without evidence of operation. A signed code of conduct is not due diligence, and buyers operating under the German and Norwegian regimes in particular will ask what the policy produced.

Two instruments not covered here

Two further regimes reach Indian suppliers but work differently enough to warrant separate treatment.

The Uyghur Forced Labor Prevention Act operates through an import prohibition with a rebuttable presumption rather than a reporting duty, and its Entity List expanded by 30 per cent in July 2026.

The EU Forced Labour Regulation, Regulation (EU) 2024/3015, applies from 14 December 2027 and prohibits products made with forced labour from the Union market entirely, with no size threshold at all. For a small Indian exporter it is likely to be the most consequential of any instrument in this field.

Frequently asked questions

Do modern slavery laws apply to Indian companies directly? No. These statutes bind buyers in the enacting jurisdiction. Indian suppliers are reached through their customers' contracts, not through the legislation itself.

What is the UK Modern Slavery Act threshold? A total turnover of £36 million or more, for commercial organisations carrying on business in the United Kingdom.

Is the UK Modern Slavery Act changing? Yes. Provisions in the Immigration and Asylum Bill, introduced 30 June 2026 and through second reading on 13 July 2026, would make statement content mandatory under a new Schedule 4ZA, extend reporting to public authorities and introduce a penalty of up to 1 per cent of turnover or £1 million, whichever is higher. The £36 million threshold is unchanged and the Bill is not yet law.

What is the Australian Modern Slavery Act threshold? Consolidated revenue of at least A$100 million for the reporting period, for an Australian entity or one carrying on business in Australia. Statements go on the Modern Slavery Statements Register, which the Minister must maintain and make publicly available without charge. The McMillan review recommended lowering the threshold to A$50 million; the Government noted rather than accepted that recommendation in its response of 2 December 2024 and retained A$100 million.

Are there penalties under the Australian Act? As at August 2026, no offence and no civil penalty, and the rules may not create either. The sanction is section 16A: the Minister may request a written explanation or remedial action and may publish the failure on the register. On 16 July 2026 the Government announced it will legislate a failure-to-prevent criminal offence and civil penalties; no Bill had been enacted at this date.

Has Germany abolished the LkSG? No. A bill would abolish the annual reporting duty retroactively from 1 January 2023 and confine fines to serious violations, but it had not completed passage when this article was prepared. The reporting form was deactivated in the autumn of 2025, on a specific date that could not be confirmed. The substantive due diligence and internal documentation obligations remain in force.

What is the German LkSG threshold? 3,000 or more employees in Germany from 1 January 2023, and 1,000 or more from 1 January 2024.

Who does the Canadian Act apply to? The test has more limbs than the two-of-three summary that circulates. An organisation is an entity if it is listed on a stock exchange in Canada, in which case no size threshold applies at all, or if it has a Canadian nexus and meets at least two of three thresholds: C$20 million in assets, C$40 million in revenue, or an average of 250 employees. Being an entity is not sufficient: section 9 adds a goods-activity test. Reports are due by 31 May annually. The Act came into force on 1 January 2024.

What are the Norwegian Transparency Act thresholds? Two routes. A public-interest entity under section 1-6 of the Accounting Act is in scope regardless of size. Otherwise an undertaking is in scope if it exceeds at least two of: sales revenue of NOK 70 million, balance sheet total of NOK 35 million, or an average of 50 full-time equivalents. The test is "exceeds", so exactly 50 full-time equivalents falls outside. Assessment is consolidated for parents, and a crossing bites only in the second of two consecutive years. This is far lower than the other regimes and catches ordinary mid-sized buyers.

What is special about the Norwegian Act? It requires substantive human rights due diligence, an annual published account by 30 June, and confers a right to information under which any member of the public may ask how the company addresses adverse impacts.

Is modern slavery regulation tightening everywhere? No. The United Kingdom is adding mandatory content and financial penalties while Germany is abolishing its reporting duty. The direction differs by jurisdiction.

What evidence do buyers actually want? A supply chain map, a documented risk assessment, policies with evidence that they operate, grievance and remediation records, audit and corrective action history, and training records.