New Template Aims to Ease Modern Slavery Reporting—But Global Compliance Remains Complex

In a collaborative move to simplify supply chain transparency reporting, the governments of the United Kingdom, Australia, and Canada have introduced a new optional template and guidance titled International Reporting on Modern Slavery, Forced Labour and Child Labour. This initiative is designed to help organizations subject to legislation in more than one of the three countries reduce administrative burden and align disclosures across borders.

HR Policy Global’s Take: while the new international tool attempts to streamline efforts across three jurisdictions, it does not eliminate the broader challenges of global compliance. Global companies must remain vigilant, tailoring their disclosures to meet the nuanced demands of each region and country they operate in.

The template outlines seven core reporting areas that organizations should address:

1. Organizational Structure and Supply Chains
2. Policies on modern slavery, forced labour, and child labour.
3. Risk Management processes to assess and address risks.
4. Due Diligence and Remediation processes and measures taken.
5. Training provided to employees.
6. Assessing Effectiveness of actions taken.
7. Additional Relevant Information (a requirement under Australian law, but optional in Canada).

It also introduces Level 1 and Level 2 disclosures:

• Level 1: Recommended baseline disclosures.
• Level 2: Voluntary, enhanced disclosures that demonstrate leadership and progress.

Importantly, the guidance encourages proportionate, risk-based reporting, emphasizing the need to tailor disclosures to the actual risk to people—not just financial or reputational risk.

A Step Forward—But Not a Global Solution

It is essential to note that this template is designed only for the UK, Australian, and Canadian jurisdictions. It is not applicable to other major jurisdictions with their own stringent modern slavery laws, such as the European Union's Corporate Sustainability Due Diligence Directive (CSDDD) or various state-level or sector-specific laws in the United States (like the California Transparency in Supply Chains Act and the Uyghur Force Labor Prevention Act).

Consequently, for global companies, this template does not eliminate the workload; it merely consolidates reporting for three specific countries. Teams will still need to conduct separate due diligence and reporting processes to comply with EU, US, and other regional regulations.