Modern Slavery Act: Australia vs UK vs Canada refers to the respective national legislative frameworks that mandate large commercial entities to disclose risks and actions related to modern slavery, forced labour, and child labour in their operations and supply chains. These laws include the UK Modern Slavery Act 2015 (Section 54), the Australian Modern Slavery Act 2018, and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211, 2023). Each law requires annual public reporting by qualifying organisations but differs in scope, thresholds, and enforcement mechanisms. These frameworks are distinct from but related to the EU Corporate Sustainability Due Diligence Directive (CSDDD) (Directive (EU) 2024/1760), which imposes mandatory due diligence obligations beyond reporting. This page provides a detailed side-by-side comparison of these three national Acts and their interaction with the EU CSDDD requirements.
Modern Slavery Act: Australia vs UK vs Canada Compared
The key difference between the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211, 2023) lies in their scope and obligations: all three require annual reporting on modern slavery risks but do not mandate direct action to prevent or remediate abuses. In contrast, the EU Corporate Sustainability Due Diligence Directive (CSDDD) (Directive (EU) 2024/1760) requires companies to identify, prevent, mitigate, and remedy adverse human rights impacts, including forced labour, thus going beyond mere disclosure. Understanding these differences is critical for compliance managers operating across these jurisdictions.
Comprehensive Comparison Table
| Dimension | UK Modern Slavery Act 2015 | Australian Modern Slavery Act 2018 | Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211, 2023) | EU CSDDD (Directive (EU) 2024/1760) |
|---|---|---|---|---|
| Legal Citation | Section 54, Modern Slavery Act 2015 (UK) | Modern Slavery Act 2018 (Australia) | Bill S-211, 2023 (Canada) | Directive (EU) 2024/1760 |
| Scope - Entities Covered | Commercial organisations with annual turnover ≥ £36 million supplying goods or services in the UK | Entities with consolidated annual revenue ≥ AUD 100 million | Government institutions and entities with ≥ 250 employees or publicly listed companies | Companies with ≥ 1,000 employees and turnover ≥ €450 million (or ≥ 250 employees and turnover ≥ €40 million in high-risk sectors) |
| Obligations | Publish annual modern slavery statement disclosing risks and actions | Submit annual modern slavery statement reporting on risks and mitigation | Report annually on forced labour and child labour risks and mitigation measures | Mandatory due diligence: identify, prevent, mitigate, and remedy adverse human rights impacts including forced labour |
| Reporting Frequency | Annual | Annual | Annual | Ongoing due diligence with periodic reporting |
| Penalties for Non-Compliance | No direct fines; reputational risk and potential civil claims | Enforceable by Australian Border Force; penalties up to AUD 1.1 million for false/misleading statements | Penalties up to CAD 250,000 for non-compliance | Fines up to 5% of global annual turnover or €20 million, whichever is higher |
| Enforcement Authority | Home Office (UK); no formal enforcement body for statements | Australian Border Force | Canadian Labour Program and other federal agencies | National competent authorities in EU Member States |
| Deadline for First Report | Annual statement due within 6 months of financial year end | First statements due by 31 March 2020; ongoing annual reporting | First reports due within 1 year of enactment (2024) | Compliance required from 1 January 2026 |
| Geographic Scope | Applies to organisations supplying goods/services in the UK | Applies to entities operating in Australia or with Australian revenue | Applies to entities operating in Canada or supplying to Canadian government | Applies to companies operating within the EU or placing products on the EU market |
| Focus | Transparency through disclosure of modern slavery risks | Transparency through disclosure of modern slavery risks | Transparency through disclosure of forced labour and child labour risks | Active due diligence and remediation of adverse human rights impacts |
Where These Laws Overlap and Diverge
All three national Acts—UK Modern Slavery Act 2015, Australian Modern Slavery Act 2018, and Canadian Bill S-211, 2023—share the common goal of increasing transparency regarding modern slavery risks in supply chains by requiring qualifying entities to publish annual statements or reports. They each set revenue or employee thresholds to determine applicability and focus on reporting rather than enforcement of direct action.
However, they diverge significantly in scope and enforcement:
- Scope and Thresholds: The UK Act applies to organisations with turnover ≥ £36 million supplying goods or services in the UK, while the Australian Act applies to entities with consolidated revenue ≥ AUD 100 million, regardless of where goods or services are supplied. The Canadian Act targets government institutions and entities with ≥ 250 employees or publicly listed companies, focusing on forced labour and child labour risks.
- Enforcement and Penalties: The UK Act lacks direct financial penalties but relies on reputational risk and potential civil litigation. Australia and Canada have introduced monetary penalties for false or misleading statements and non-compliance, with fines up to AUD 1.1 million and CAD 250,000 respectively.
- Obligations: All three require annual reporting but do not mandate companies to take active steps to prevent or remediate modern slavery. In contrast, the EU CSDDD (Directive (EU) 2024/1760) requires companies to implement comprehensive due diligence processes, including prevention, mitigation, and remediation of adverse human rights impacts.
- Geographic Reach: The UK and Australian Acts apply to entities supplying goods or services within their jurisdictions, while the Canadian Act applies to entities operating in Canada or supplying to the Canadian government. The EU CSDDD applies broadly to companies operating or placing products on the EU market.
Which Law Applies to You?
Determining which modern slavery law applies depends on your organisation’s size, revenue, employee count, and geographic footprint:
- UK Modern Slavery Act 2015: Applies if your organisation has an annual turnover of £36 million or more and supplies goods or services in the UK.
- Australian Modern Slavery Act 2018: Applies if your entity’s consolidated annual revenue is AUD 100 million or more, regardless of where goods or services are supplied, provided you operate or have a presence in Australia.
- Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211, 2023): Applies if you are a government institution or an entity with 250 or more employees or publicly listed in Canada.
- EU CSDDD (Directive (EU) 2024/1760): Applies if your company has 1,000 or more employees and a turnover of at least €450 million, or 250 or more employees and €40 million turnover in high-risk sectors, and operates within or places products on the EU market.
If your organisation meets thresholds in multiple jurisdictions, you must comply with each applicable law independently. Notably, the EU CSDDD’s due diligence requirements are more stringent and action-oriented than the reporting-focused national Acts.
Truth Anchor: The EU Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760) mandates compliance starting from 1 January 2026 with penalties up to 5% of global annual turnover or €20 million, whichever is higher, for failure to conduct adequate human rights due diligence.
Frequently Asked Questions
Q1: Does the UK Modern Slavery Act require companies to take action to prevent modern slavery?
A1: No. The UK Modern Slavery Act 2015 (Section 54) requires only that qualifying organisations publish an annual statement disclosing the steps they have taken to assess and address modern slavery risks. It does not mandate direct prevention or remediation actions.
Q2: How do the Australian and Canadian modern slavery laws differ in enforcement?
A2: The Australian Modern Slavery Act 2018 is enforced by the Australian Border Force and includes penalties up to AUD 1.1 million for false or misleading statements. The Canadian Bill S-211, 2023, imposes penalties up to CAD 250,000 for non-compliance and is enforced by federal labour authorities. The UK Act has no direct financial penalties.
Q3: If my company operates in both the EU and Australia, which requirements should I follow?
A3: You must comply with both the Australian Modern Slavery Act 2018 and the EU CSDDD (Directive (EU) 2024/1760) if your company meets the respective thresholds. The EU CSDDD requires active due diligence beyond reporting, so compliance with it will generally exceed Australian reporting obligations.
Q4: What are the key deadlines for reporting under these laws?
A4: The UK requires annual statements within six months of the financial year end. Australia’s first statements were due by 31 March 2020, with ongoing annual reporting. Canada’s Bill S-211 requires first reports within one year of enactment (2024). The EU CSDDD compliance begins on 1 January 2026.
Q5: Can I use one report to satisfy all these laws?
A5: While some information may overlap, each law has specific content and format requirements. It is advisable to tailor reports to each jurisdiction’s legal obligations to ensure full compliance and avoid penalties.
Related Compliance Resources
Get Started with Your Compliance Reporting
Use our dedicated Modern Slavery Compliance Tool to generate tailored reports for the UK, Australia, Canada, and align with EU CSDDD due diligence requirements. The tool guides you step-by-step through the reporting process, ensures you meet all legal thresholds, and helps you avoid penalties up to 5% of global turnover under the EU CSDDD.
Clicking the link will open the compliance tool where you can enter your company details and receive a customised compliance roadmap and report templates.