Guides / AU procurement / Modern slavery

Modern slavery

The reporting duty covers large entities. The questionnaire covers you.


The Modern Slavery Act 2018 compels entities over $100 million in consolidated revenue to publish annual statements. But tenders ask suppliers of every size for supply-chain evidence, contractually. Part of our guide on Australian government procurement.

Published: 16 September 2026 · By Bill · Reviewed by Andre · selrob

Takeaways

  • Statutory reporting applies at $100 million consolidated revenue; check the current Act for the figure. Most readers of this page are below it.
  • Buyer questionnaires and contract clauses apply regardless of size. That is the obligation that bites.
  • A questionnaire answered with intentions instead of controls is a risk finding, not a pass.

Who must report under the Act?

Entities carrying on business in Australia with $100 million or more in annual consolidated revenue must publish yearly modern slavery statements on the public register, describing risks in operations and supply chains, actions taken, and effectiveness. Confirm the threshold against the current Act before relying on it; thresholds are the kind of figure that moves while summaries stand still. Commonwealth entities are also covered by reporting expectations of their own.

If your firm is under the threshold, the Act does not require a statement from you. Read on anyway, because the tender in front of you does.

What do buyers actually ask?

Questionnaires on supply-chain mapping, risk assessment, due diligence, remediation processes, and training, plus contract clauses that oblige ongoing compliance, notification of issues, and cooperation with audits. These bind by contract, not by statute, which means they bind at any revenue. A small consultancy with a cleaning subcontractor and an offshore development team will answer questions about both.

State provisions can add their own layer; check the buyer’s jurisdiction rather than assuming the Commonwealth Act is the whole picture. The pack’s clauses decide; this page frames the reading.

What counts as evidence?

  • Mapping. Which suppliers and subcontractors, in which countries, for which inputs. Named, not “various”.
  • Risk assessment. Where the risks sit and why: product, geography, workforce model.
  • Controls. Contract terms, audits, training, grievance channels, operating, not planned.
  • Remediation. What happens when an issue surfaces: process with an owner, not a paragraph of concern.

What does this mean for the bid/no-bid call?

If the questionnaire demands controls you do not operate, the response cannot be written honestly in the time available; that is a review turning rapidly into a no. If the controls exist, answering is demonstration work. The contractual home for these obligations is often the Supplier Code of Conduct sitting in the same contract. Subcontractor flow-down, who owes what to whom, is read the way subcontracting restrictions describes.

Keep reading

Elsewhere in this guide.

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