Quarterly BAS Due (July–September)
Form 1099-NEC & Contractor Payment Reporting Check
Why this matters.
Section 54 of the Modern Slavery Act 2015 requires every commercial organisation with an annual turnover of £36 million or more that supplies goods or services in the UK to publish an annual transparency statement. The statement must be approved by the board of directors (or equivalent) and set out the steps taken — or confirm that no steps have been taken — to ensure modern slavery is not occurring in the organisation’s business or supply chains. Since 2021, statements must be published on the Government’s official modern slavery statement registry. The Government updated its guidance in March 2025, making it explicit that organisations should map their supply chains beyond direct (tier-1) suppliers to understand indirect supply chain risks. For organisations with a 31 December financial year end, the transparency statement covering the 2025 financial year had to be published by 30 June 2026 — organisations that missed this should publish as soon as possible to limit exposure.
Enforcement has been escalating. The Home Office has named non-compliant businesses in letters to FTSE 350 companies, and an independent review has recommended mandatory reporting with civil penalties. Beyond the statutory obligation, procurement teams at large buyers, institutional investors, and government frameworks increasingly require evidence of robust modern slavery due diligence as a condition of contract. The updated 2025 guidance identifies six areas every statement should cover: organisational structure and supply chains; policies; due diligence processes; risk assessment and management; key performance indicators; and training. Even businesses below the £36 million threshold often receive contractual obligations from larger customers requiring equivalent standards — making this framework highly relevant across the supply chain.
