Modern Slavery Reporting in 2026: What the Commissioner’s Recommendations Mean for Business

For businesses with a 30^th June financial year, the next Modern Slavery Statement is due by 31^st December 2026. Under the Modern Slavery Act 2018 (Cth), entities operating in Australia with at least $100 million in annual consolidated revenue must report on how they assess and address modern slavery risks in their operations and supply chains.

The immediate requirement has not changed. However, in January 2026, the Office of the Australian Anti-Slavery Commissioner released an Initial Position Paper recommending reforms to strengthen the Act. Published to inform the Australian Government’s consideration of potential reforms, the paper signals that future expectations could extend well beyond annual reporting.

What could change for businesses?

Australia’s current modern slavery framework is largely disclosure-based – while businesses must describe their risks and actions, the Act does not prescribe a minimum level of due diligence that must be undertaken. The Commissioner argues that while this approach has improved awareness of the issue, it has not produced sufficiently consistent or effective action.

The Commissioner thus recommends a mandatory, risk-based modern slavery due diligence obligation for reporting entities and a mechanism for the Commissioner to declare particular products, services or industries as high-risk, which businesses would need to consider in their due diligence and reporting.

In practice, this could mean that businesses would need to take reasonable measures to:

• Embed due diligence into policies and systems
• Identify, assess, and prioritise the most severe and likely risks of harm to people
• Take action to address those risks including ceasing, preventing, or mitigating risks
• Track implementation of actions and whether they are effective
• Communicate how risks are addressed in the statement (including reporting on these steps)
• Provide accessible grievance mechanisms to receive concerns
• Cooperate in remediation where the business has caused or contributed to harm or use its leverage to influence remediation where it is directly linked to harm
• Engage workers and affected stakeholders in a meaningful and ongoing manner

These preliminary recommendations were released to help stakeholders consider the reforms under consultation. If adopted, they would shift expectations beyond transparency towards a more pragmatic, risk-based approach in which businesses must not only report on modern slavery risks, but demonstrate how they are identifying, prioritising and addressing them.

 Why start now?

Modern slavery due diligence cannot be built at the point of drafting the annual statement. The 31^st December 2026 deadline may be the immediate focus, but the more important question is whether the systems behind the statement are robust and operating effectively.

Businesses that begin strengthening governance, supplier engagement, grievance processes and monitoring now will be better prepared – both for this year’s reporting and for the direction Australia’s modern slavery framework may take. Contact us to find out how Cress Consulting can help your business today.

Cress is the Hydroflux Group’s in-house sustainability consulting team, operating as a specialised division and driven by a simple but powerful goal: to help organisations across Australia, New Zealand and the Pacific region create a more sustainable future. As a young and agile team, we combine technical expertise with fresh, forward-thinking approaches to help clients navigate complex challenges across climate risk, emissions reduction, modern slavery, water stewardship, and ESG reporting, building on the Hydroflux legacy of engineering excellence while bringing a sustainability lens to the industries and communities shaping the future of our region.