Compliance · Supply chain
Your print business almost certainly does not have to file a modern slavery statement. Your customers do
If a corporate client has sent you a supplier questionnaire asking where your paper comes from and who audits your suppliers, this is why. The Modern Slavery Act catches entities with consolidated revenue of at least $100 million, which excludes nearly every printer in the country. It then makes those large entities describe their supply chains, their due diligence, and how they know any of it is working. You are the supply chain.
Whether it applies to you
Section 5 defines a reporting entity. The core limb is
an entity which has a consolidated revenue of at least $100 million for the reporting
period
, where that entity is Australian or
carries on business in Australia at any time in that reporting period
. The Commonwealth
and Commonwealth entities above the same threshold are also caught.
There is one other route in, and it is voluntary:
an entity which has volunteered to comply with the requirements of this Act
under
section 6. A printer that wants a statement on the register for commercial reasons can file
one without being obliged to.
For almost every business in this trade, the answer is that the Act does not require anything of you directly. That is not the end of it.
Why the questionnaires arrive
Section 16 sets out what a reporting entity's statement must contain, and two of the
mandatory criteria reach straight into its suppliers. The statement must
describe the structure, operations and supply chains of the reporting entity
, and
describe the risks of modern slavery practices in the operations and supply chains of the
reporting entity
and any entities it owns or controls.
Then it must describe the actions taken to assess and address those risks,
including due diligence and remediation processes
. Due diligence on a supply chain means
asking the suppliers. That is the questionnaire.
The criterion that turns a questionnaire into an audit
One requirement does more work than the rest. A statement must
describe how the reporting entity assesses the effectiveness of such actions
.
It is not enough for a customer to say it sent a questionnaire. It has to say how it knows the answers mean anything. That is what escalates a one-page form into requests for certifications, site visits, evidence about sub-contractors and questions about where your own inputs come from. The pressure you feel is a reporting obligation being pushed one link down the chain, which is exactly how the Act was designed to work.
And it is signed off at the top. A single-entity statement must include
details of approval by the principal governing body of the reporting entity
. A board has
put its name to the answers your questionnaire fed into, which is why the deadlines are firm
and the follow-ups are persistent.
What happens if a reporting entity does not report
This is the part most commentary gets wrong or leaves stale. The Act carries no fine for failing to lodge. What it now has, since the compilation current at the time of writing, is a sequence.
If the Minister is reasonably satisfied an entity has failed to comply, the Minister may
request that it provide an explanation for the failure to comply within a specified period
of 28 days or longer
, or undertake specified remedial action in relation to that
requirement
, or both. If the entity then fails to comply with that request,
the Minister may publish the following information on the register
.
So the sanction is publication rather than penalty. For a company whose customers read the register, that is not nothing, but it is worth being precise: there is no civil penalty for failing to report.
There is now a Commissioner, and part of the job is helping you
The Act now establishes an Australian Anti-Slavery Commissioner. Among the functions are
to promote compliance with this Act
and, more usefully for a supplier,
to support Australian entities and entities carrying on business in Australia to address
risks of modern slavery practices in their operations and supply chains
.
That function is not limited to reporting entities. A printer trying to answer a customer's questionnaire honestly is exactly the kind of business it names.
Our view
Labelled as opinion, on the sections above. The design is sound and the burden lands awkwardly. Putting the obligation on large buyers rather than on every small supplier is the right choice, and the effectiveness criterion is what stops it becoming paperwork. But the cost of answering falls on businesses with no obligation under the Act, no threshold to hide behind and no ability to charge for the work.
The practical response for a printer is to answer once, properly, and keep it. Most of what customers ask for is the same set of facts about paper sourcing, sub-contracting and labour hire. A standing supplier pack costs a day and saves that day repeatedly, and it is a commercial advantage with the kind of customer who has to file.
What this page does not tell you
It is a description of the Act, not legal advice, and it does not set out the reporting periods, the joint statement rules or the register mechanics. Whether a particular business meets the revenue threshold depends on the Act's definition of consolidated revenue, which this page does not reproduce. Nothing here says what any customer is entitled to demand of a supplier, which is a matter of contract rather than of this Act. The compilation number is stated because the Act has been amended and may be again.
Sources
- Modern Slavery Act 2018, compilation No. 2, in force from 7 November 2024 (authorised PDF, downloaded and read 27 Aug 2026): section 5 on the meaning of reporting entity, including the $100 million consolidated revenue threshold, the Australian entity and carrying on business limbs and the Commonwealth entities; section 6 and the voluntary route; section 16 and its mandatory criteria, including describing structure, operations and supply chains, describing modern slavery risks in those supply chains, describing actions taken including due diligence and remediation processes, describing how the entity assesses the effectiveness of those actions, and the requirement for approval by the principal governing body; section 16A on requests for an explanation or remedial action, the 28 day minimum period and the publication of a failure to comply; and Part 3A establishing the Australian Anti-Slavery Commissioner together with the functions quoted.
Methodology. Every quotation is from the Act as compiled, downloaded from the Federal Register of Legislation and read directly, rather than from guidance about the Act. The compilation number is on the page because this Act has been amended since it was made, and the amendment matters here: the request-and-publish mechanism and the Anti-Slavery Commissioner are both in the current compilation and are absent from commentary written against the original 2018 text. Where this page summarises a provision rather than quoting it, that is signalled. We say there is no civil penalty for failing to report because the Act's operative sections carry none, and we have said what exists instead rather than leaving the impression the obligation is unenforceable. No company, supplier or customer is named anywhere on this page.
Spotted an error, or has the Act been amended again? Tell us and we will check it against the Act and log the outcome here.