How UK Boards Should Govern Modern Slavery Compliance in 2026

Executive Action:

• Treat the current statement as a dry run for a mandatory, standardised format — gaps found now are cheaper to fix than gaps found under a fixed deadline.
• Assign board-level ownership of Section 54 to a named committee (typically Audit or Risk) ahead of any published sector list.
• Map EU-facing product lines against the Forced Labour Regulation’s December 2027 deadline now.

How Should the Board Structure Its Review Before Sign-Off?

A credible board review treats the statement as a risk disclosure, not a communications document. That means testing three things before signature: whether the due diligence described was actually performed and evidenced, whether high-risk suppliers identified in prior years show measurable remediation rather than repeated flagging, and whether the statement would withstand scrutiny from a public sector procurement team applying the new NHS risk assessment or a journalist comparing it against the government’s forthcoming sector list. Boards that already run capital or technology approvals through a formal assessment framework should apply the same discipline here — Section 54 sign-off deserves the same rigour as a capital allocation decision, not less.

Executive Action:

• Require a year-on-year comparison showing remediation of previously flagged high-risk suppliers, not just re-disclosure.
• Use a structured review framework rather than sign-off by exception — INFORMD’s assessment tools (/tools-assessments/) offer a starting checklist.
• Set a standing annual board agenda item for Section 54 review, owned by a named committee with minuted challenge.

INFORMD provides intelligence briefings, tools and frameworks for senior business leaders across technology, finance, strategy and compliance. Based in Milton Keynes, UK, we help executives stay informed and act with confidence. Explore our full briefing library (/resources/) or access our free assessment tools (/tools-assessments/). For board-level supply chain and third-party risk frameworks, see our templates (/templates/), or get in touch (/contact/) to discuss your governance programme.

Stay ahead. Subscribe to INFORMD’s weekly executive briefing at informd.co.uk (/resources/).

Executive Action:

• Assess public sector revenue exposure and flag contracts that will fall under the NHS 2025 regulations from May 2026.
• Brief procurement and bid teams that a non-compliant statement can now trigger mandatory exclusion under the Procurement Act 2023.
• Pressure-test whether the business could complete an MSAT assessment today, not just draft a statement.

What Reforms to Section 54 Should the Board Anticipate?

Government proposals under consideration would move Section 54 from a “comply or explain” disclosure regime toward mandatory content. Under the proposed changes, statements would need to cover specific reporting areas rather than allow organisations to opt out of any of them, follow a standardised format, and meet a fixed annual submission deadline instead of the current flexibility around financial year-end. The government has also proposed publishing a public list of organisations required to report under Section 54, categorised by sector — turning non-compliance into a visible, sector-benchmarked failure rather than a private one. Separately, UK companies placing products on the EU market have a longer runway to prepare for the EU Forced Labour Regulation, which prohibits forced-labour-tainted goods from sale in the EU from December 2027.

Executive Action:

• Treat the current statement as a dry run for a mandatory, standardised format — gaps found now are cheaper to fix than gaps found under a fixed deadline.
• Assign board-level ownership of Section 54 to a named committee (typically Audit or Risk) ahead of any published sector list.
• Map EU-facing product lines against the Forced Labour Regulation’s December 2027 deadline now.

How Should the Board Structure Its Review Before Sign-Off?

A credible board review treats the statement as a risk disclosure, not a communications document. That means testing three things before signature: whether the due diligence described was actually performed and evidenced, whether high-risk suppliers identified in prior years show measurable remediation rather than repeated flagging, and whether the statement would withstand scrutiny from a public sector procurement team applying the new NHS risk assessment or a journalist comparing it against the government’s forthcoming sector list. Boards that already run capital or technology approvals through a formal assessment framework should apply the same discipline here — Section 54 sign-off deserves the same rigour as a capital allocation decision, not less.

Executive Action:

• Require a year-on-year comparison showing remediation of previously flagged high-risk suppliers, not just re-disclosure.
• Use a structured review framework rather than sign-off by exception — INFORMD’s assessment tools (/tools-assessments/) offer a starting checklist.
• Set a standing annual board agenda item for Section 54 review, owned by a named committee with minuted challenge.

INFORMD provides intelligence briefings, tools and frameworks for senior business leaders across technology, finance, strategy and compliance. Based in Milton Keynes, UK, we help executives stay informed and act with confidence. Explore our full briefing library (/resources/) or access our free assessment tools (/tools-assessments/). For board-level supply chain and third-party risk frameworks, see our templates (/templates/), or get in touch (/contact/) to discuss your governance programme.

Stay ahead. Subscribe to INFORMD’s weekly executive briefing at informd.co.uk (/resources/).

Executive Action:

• Confirm which entities in the group meet the £36 million turnover threshold and file individually if required.
• Request the underlying evidence for each reporting area before signing — not just the drafted narrative.
• Record board review of the statement in minutes, showing genuine scrutiny rather than approval by circulation.

Why Is a Procurement Regulation Now a Board Risk?

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 come into force on 17 May 2026, and they change the commercial consequences of a weak modern slavery statement. From that date, public bodies procuring for the NHS in England must complete a modern slavery risk assessment before advertising a contract, and for medium- and high-risk procurements they can require suppliers to complete the Modern Slavery Assessment Tool (MSAT) as a condition of participation. The regulations apply regardless of contract value and sit alongside the existing Procurement Act 2023 exclusion ground, under which a contracting authority must exclude a supplier that has failed to produce a required Section 54 statement.

According to a 2023 supply chain review cited by NHS England, across 60% of spend on medical consumables, 21% of suppliers were identified as high risk for modern slavery and a further 16% as medium risk — the evidence base behind the new regime. For any supplier with NHS or wider public sector revenue, a Section 54 statement is no longer a website disclosure; it is a live procurement qualification document that can determine whether the business is even eligible to bid.

Executive Action:

• Assess public sector revenue exposure and flag contracts that will fall under the NHS 2025 regulations from May 2026.
• Brief procurement and bid teams that a non-compliant statement can now trigger mandatory exclusion under the Procurement Act 2023.
• Pressure-test whether the business could complete an MSAT assessment today, not just draft a statement.

What Reforms to Section 54 Should the Board Anticipate?

Government proposals under consideration would move Section 54 from a “comply or explain” disclosure regime toward mandatory content. Under the proposed changes, statements would need to cover specific reporting areas rather than allow organisations to opt out of any of them, follow a standardised format, and meet a fixed annual submission deadline instead of the current flexibility around financial year-end. The government has also proposed publishing a public list of organisations required to report under Section 54, categorised by sector — turning non-compliance into a visible, sector-benchmarked failure rather than a private one. Separately, UK companies placing products on the EU market have a longer runway to prepare for the EU Forced Labour Regulation, which prohibits forced-labour-tainted goods from sale in the EU from December 2027.

Executive Action:

• Treat the current statement as a dry run for a mandatory, standardised format — gaps found now are cheaper to fix than gaps found under a fixed deadline.
• Assign board-level ownership of Section 54 to a named committee (typically Audit or Risk) ahead of any published sector list.
• Map EU-facing product lines against the Forced Labour Regulation’s December 2027 deadline now.

How Should the Board Structure Its Review Before Sign-Off?

A credible board review treats the statement as a risk disclosure, not a communications document. That means testing three things before signature: whether the due diligence described was actually performed and evidenced, whether high-risk suppliers identified in prior years show measurable remediation rather than repeated flagging, and whether the statement would withstand scrutiny from a public sector procurement team applying the new NHS risk assessment or a journalist comparing it against the government’s forthcoming sector list. Boards that already run capital or technology approvals through a formal assessment framework should apply the same discipline here — Section 54 sign-off deserves the same rigour as a capital allocation decision, not less.

Executive Action:

• Require a year-on-year comparison showing remediation of previously flagged high-risk suppliers, not just re-disclosure.
• Use a structured review framework rather than sign-off by exception — INFORMD’s assessment tools (/tools-assessments/) offer a starting checklist.
• Set a standing annual board agenda item for Section 54 review, owned by a named committee with minuted challenge.

INFORMD provides intelligence briefings, tools and frameworks for senior business leaders across technology, finance, strategy and compliance. Based in Milton Keynes, UK, we help executives stay informed and act with confidence. Explore our full briefing library (/resources/) or access our free assessment tools (/tools-assessments/). For board-level supply chain and third-party risk frameworks, see our templates (/templates/), or get in touch (/contact/) to discuss your governance programme.

Stay ahead. Subscribe to INFORMD’s weekly executive briefing at informd.co.uk (/resources/).

UK boards must approve their Modern Slavery Act 2015 statement annually — from May 2026, a weak one can disqualify a supplier from NHS contracts.

Section 54 of the Modern Slavery Act 2015 requires any commercial organisation with turnover above £36 million to publish an annual statement describing the steps it has taken to identify and address slavery and human trafficking in its operations and supply chains. That statement must be approved by the board and signed by a director. For a decade, many boards treated this as a compliance formality, delegated to legal or procurement teams and signed without much scrutiny. Two regulatory developments in 2026 make that approach untenable.

What Does Section 54 Actually Require of the Board?

Section 54 does not mandate specific actions against modern slavery — it mandates disclosure. In-scope organisations must publish a statement covering their structure, supply chains, policies, due diligence, risk assessment, effectiveness measures and staff training, or explain why a given area is not covered. The statement must be published on the organisation’s website and, since 2021, filed on the government’s Modern Slavery Statement Registry. Crucially, the Act requires sign-off “by a director” (or equivalent), which the Home Office’s statutory guidance treats as a substantive governance act, not a rubber stamp. A board that has not asked what due diligence was actually performed cannot credibly approve the statement it is signing.

According to the UK Home Office’s Transparency in Supply Chains (TISC) statutory guidance, updated in March 2025, organisations are now expected to provide more detailed, evidence-based disclosure across each reporting area rather than generic policy language — a direct response to years of statements that satisfied the letter of Section 54 while disclosing almost nothing of substance.

Executive Action:

• Confirm which entities in the group meet the £36 million turnover threshold and file individually if required.
• Request the underlying evidence for each reporting area before signing — not just the drafted narrative.
• Record board review of the statement in minutes, showing genuine scrutiny rather than approval by circulation.

Why Is a Procurement Regulation Now a Board Risk?

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 come into force on 17 May 2026, and they change the commercial consequences of a weak modern slavery statement. From that date, public bodies procuring for the NHS in England must complete a modern slavery risk assessment before advertising a contract, and for medium- and high-risk procurements they can require suppliers to complete the Modern Slavery Assessment Tool (MSAT) as a condition of participation. The regulations apply regardless of contract value and sit alongside the existing Procurement Act 2023 exclusion ground, under which a contracting authority must exclude a supplier that has failed to produce a required Section 54 statement.

According to a 2023 supply chain review cited by NHS England, across 60% of spend on medical consumables, 21% of suppliers were identified as high risk for modern slavery and a further 16% as medium risk — the evidence base behind the new regime. For any supplier with NHS or wider public sector revenue, a Section 54 statement is no longer a website disclosure; it is a live procurement qualification document that can determine whether the business is even eligible to bid.

Executive Action:

• Assess public sector revenue exposure and flag contracts that will fall under the NHS 2025 regulations from May 2026.
• Brief procurement and bid teams that a non-compliant statement can now trigger mandatory exclusion under the Procurement Act 2023.
• Pressure-test whether the business could complete an MSAT assessment today, not just draft a statement.

What Reforms to Section 54 Should the Board Anticipate?

Government proposals under consideration would move Section 54 from a “comply or explain” disclosure regime toward mandatory content. Under the proposed changes, statements would need to cover specific reporting areas rather than allow organisations to opt out of any of them, follow a standardised format, and meet a fixed annual submission deadline instead of the current flexibility around financial year-end. The government has also proposed publishing a public list of organisations required to report under Section 54, categorised by sector — turning non-compliance into a visible, sector-benchmarked failure rather than a private one. Separately, UK companies placing products on the EU market have a longer runway to prepare for the EU Forced Labour Regulation, which prohibits forced-labour-tainted goods from sale in the EU from December 2027.

Executive Action:

• Treat the current statement as a dry run for a mandatory, standardised format — gaps found now are cheaper to fix than gaps found under a fixed deadline.
• Assign board-level ownership of Section 54 to a named committee (typically Audit or Risk) ahead of any published sector list.
• Map EU-facing product lines against the Forced Labour Regulation’s December 2027 deadline now.

How Should the Board Structure Its Review Before Sign-Off?

A credible board review treats the statement as a risk disclosure, not a communications document. That means testing three things before signature: whether the due diligence described was actually performed and evidenced, whether high-risk suppliers identified in prior years show measurable remediation rather than repeated flagging, and whether the statement would withstand scrutiny from a public sector procurement team applying the new NHS risk assessment or a journalist comparing it against the government’s forthcoming sector list. Boards that already run capital or technology approvals through a formal assessment framework should apply the same discipline here — Section 54 sign-off deserves the same rigour as a capital allocation decision, not less.

Executive Action:

• Require a year-on-year comparison showing remediation of previously flagged high-risk suppliers, not just re-disclosure.
• Use a structured review framework rather than sign-off by exception — INFORMD’s assessment tools (/tools-assessments/) offer a starting checklist.
• Set a standing annual board agenda item for Section 54 review, owned by a named committee with minuted challenge.

INFORMD provides intelligence briefings, tools and frameworks for senior business leaders across technology, finance, strategy and compliance. Based in Milton Keynes, UK, we help executives stay informed and act with confidence. Explore our full briefing library (/resources/) or access our free assessment tools (/tools-assessments/). For board-level supply chain and third-party risk frameworks, see our templates (/templates/), or get in touch (/contact/) to discuss your governance programme.

Stay ahead. Subscribe to INFORMD’s weekly executive briefing at informd.co.uk (/resources/).