Do small businesses need a modern slavery statement?

No, most small businesses do not need a modern slavery statement. The legal duty only applies to commercial organisations carrying on business in the UK with total turnover of £36 million or more. If you are below that, you can still be asked about modern slavery by customers and in tenders, and a clear answer about your policies and supplier checks, or a short voluntary statement, covers it well.

So if the question has just appeared on a customer’s supplier form and you are wondering whether you have missed a legal requirement, you almost certainly have not. Here is who the law applies to, why the question comes up anyway, and how to answer it with confidence.

Who legally needs a modern slavery statement?

Section 54 of the Modern Slavery Act 2015 applies to a commercial organisation that:

• is a body corporate or a partnership, wherever it was set up
• carries on a business, or part of a business, in the UK
• supplies goods or services
• has a total annual turnover of £36 million or more

That turnover figure includes the turnover of any subsidiaries, even ones operating wholly outside the UK. So a small UK company owned by a large group may be covered by its parent’s statement.

If you are in scope, the statement must be published every financial year. It has to be approved by the board (or equivalent) and signed by a director, and if you have a website, you must publish it there with a link in a prominent place on the homepage. The government’s practical guide asks organisations to publish within six months of their financial year end.

For context, a business turning over £36 million is far larger than most UK small businesses. A 12-person accountancy practice, a café group with three sites or a 40-person joinery firm will all be well below it.

Why are customers asking small suppliers about it?

Because their own statement depends on you. A business over the threshold has to describe the steps it takes to stop slavery and human trafficking in its business and supply chains. You are part of that supply chain, so they ask.

It shows up in a few places:

• Supplier questionnaires from larger customers, often with a question like “Do you have a modern slavery statement?” or “How do you assess modern slavery risk in your supply chain?”
• Public sector tenders, where the selection questions frequently include modern slavery alongside other compliance checks.
• Onboarding forms for big retailers, manufacturers and facilities firms.

None of this means the customer expects a 20-page statement from a 10-person firm. They want to know you have thought about it and taken proportionate steps.

Should a small business write a voluntary statement?

It depends on who you sell to. A voluntary statement is worth considering if:

• you supply large retailers, manufacturers or public bodies that ask for one regularly
• you work in a sector with higher labour exploitation risks, such as cleaning, construction, hospitality, food production, textiles or logistics
• you buy goods made overseas, especially clothing, electronics or packaging

If none of those apply, a short anti-slavery commitment in your code of conduct, plus a sentence about how you check suppliers, is often all a customer needs. Our guide to a code of conduct for a small business explains what that document usually covers.

If you do publish a voluntary statement, you can add it to the government’s modern slavery statement registry, which accepts statements from organisations that are not legally required to publish. Keep it honest. A statement that describes checks you do not actually carry out is worse than no statement at all.

What goes in a modern slavery statement?

Government guidance encourages statements to cover six areas. For a small business, each can be short and practical:

1. Structure, business and supply chains. What you do, where you operate, roughly how many suppliers you use and where they are based.
2. Policies. Which of your policies address forced labour, fair recruitment and whistleblowing.
3. Due diligence. What you check before and after taking on a supplier, and what you would do if you found a problem.
4. Risk assessment. Which parts of your business or supply chain carry more risk, and why.
5. Effectiveness. How you know your steps are working, such as the share of key suppliers that have confirmed compliance.
6. Training. Who in your team understands the signs of modern slavery and how they learned.

A UK-based design studio with 15 suppliers, nearly all UK service firms, might cover all six in a single page. A clothing brand sourcing from factories abroad would need far more detail on risk and due diligence.

If you write a voluntary statement, date it, have a director sign it and review it once a year. Describe what you did in the last 12 months rather than what you intend to do one day. A short statement that says “we asked our eight main suppliers to confirm compliance and all eight did” is more convincing than a long one full of general commitments.

How to answer the modern slavery question on a supplier questionnaire

Here are three honest answers for common situations. Adapt them to what you really do.

A small service business with UK suppliers:

We are below the £36 million turnover threshold in section 54 of the Modern Slavery Act 2015, so we are not required to publish a statement. Our code of conduct prohibits forced and child labour. We carry out right to work checks for all staff, and our main suppliers are UK-based service providers.

A business with some formal supplier checks:

We are not required to publish a statement. We ask all new suppliers to confirm in writing that they comply with the Modern Slavery Act 2015, and we review our ten largest suppliers each year.

A business with gaps it is working on:

We are below the threshold and do not yet have a formal supplier due diligence process. We plan to introduce supplier confirmation of compliance by March 2027.

That third answer is perfectly acceptable. Buyers generally respond far better to a gap with a plan than to an answer that overclaims. Our guide on how to answer a supplier sustainability questionnaire has more example wording.

How ESG Now helps

ESG Now does not write a modern slavery statement for you. What it does is record the facts a customer or a statement would draw on, so you have them in one place.

The governance section asks whether you have a modern slavery statement, whether your supplier due diligence is formal, informal or not yet in place, how many suppliers you use and whether they are mostly UK-based, and your payment terms. It also records whether you have a code of conduct and what it covers, such as anti-bribery and whistleblowing. Each practice is marked established, developing, not in place, not applicable or unknown, without scoring you against anyone else.

Your private action plan then lists the policies worth adding next. If a statement or supplier checks would help with the customers you serve, it may flag them there. Meanwhile, your ESG report gives you a shareable record of your governance, people and environmental practices to attach to the rest of the questionnaire.

How long will yours take?

Pick the option that sounds most like your business. You will see a realistic time, what to have nearby and a head start on the questions.

Which sounds most like you?

Sole trader working from homeConsultants, designers, developers, coaches10 to 15 minSole trader or freelancer in a co-working spaceA desk at a WeWork, Regus or local hub10 to 15 minSmall team in a co-working or serviced officeStartups and agencies with 2 to 25 people15 to 20 minSME with its own office and no vehiclesProfessional services, tech firms, studios20 to 30 minSME with vans, cars or regular staff travelTrades, field services, consultancies on the road30 to 45 minShop, cafe, workshop or product businessRetail, hospitality, makers and manufacturers30 to 45 min

Your estimate

About 20 to 30 minutes

Around 50 questions, most of them multiple choice

Still comfortably under half an hour.

You will add your electricity and gas use, plus a quick estimate of your bins. If you do not have the exact figures, the questionnaire works them out from your floor area instead.

Handy to have nearby

• A recent electricity and gas bill (or your office size in square metres)
• How many general waste and recycling bins you have
• Headcount and a rough idea of business trains and flights
• How your team usually gets to work

Missing something? Estimates are fine, and you can come back to any answer later.

Office-based firms usually have clear, low-cost ways to cut their footprint. Your action plan will list them in order.

Start with this profile

First report free. No card needed.

Start with what you already do

Most small businesses already take sensible steps without calling them modern slavery due diligence: right to work checks, paying fairly, using suppliers they know well. Writing those down is the main job, and it rarely takes more than an hour.

Your ESG Now report puts those practices in writing alongside your carbon footprint, so the whole supplier questionnaire gets easier, not just this question. Your first report is free, with no card needed. An office-based business usually finishes in 20 to 30 minutes, and answers save as you go.

Start your report and give your customer a clear answer this week. For more on customer requests, see our supplier questionnaires hub, or read the short modern slavery statement definition.