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What organisations need to know about modern slavery law changes 

Modern slavery is no longer just a compliance or reputational issue for organisations. A new law means companies could now face criminal prosecution for offences committed by senior managers. 

From 29 June 2026, a significant legal change came into force under Section 250 of the Crime and Policing Act 2026. While it may sound like a technical update, it represents a major shift in how organisations are held accountable for modern slavery risk.  

This is not just a compliance update, it’s a change that brings modern slavery firmly into the realm of criminal risk.  

What’s changed? 

Historically, it has been very difficult to prosecute companies for criminal offences.  

Previously, companies could usually only be held accountable if a board-level executive was involved in the wrongdoing.  

This began to change with the Economic Crime and Corporate Transparency Act 2023, but only for specific offences like fraud.  

Section 250 goes much further.  

It extends corporate criminal liability to all criminal offences – including those connected to the Modern Slavery Act 2015.  

In simple terms, if a senior manager commits a modern slavery offence while doing their job, the organisation itself can now be prosecuted.  

Who counts as a ‘senior manager’? 

This law is not about job titles – it’s about practical responsibility and influence.  

A senior manager is anyone who:  

  • Plays a significant role in decision-making, or  
  • Manages a substantial part of the business.  

In a modern slavery context, this could include:  

  • A head of procurement overriding supplier checks.  
  • A logistics lead approving risky subcontractors.  
  • An operations manager ignoring signs of exploitation on-site.  

A key point to understand:  

  • The individual does not need board approval for decision-making.  
  • If they are acting within their actual or apparent authority, their actions can be attributed to the company.  

 

Why this matters: a shift in modern slavery risk 

For many organisations, modern slavery compliance has historically been seen as a reporting and reputational issue.  

That is no longer the case.  

Before  

  • A focus on transparency statements (Section 54, Modern Slavery Act).  
  • Risk of public criticism or lost contracts.  
  • Legal consequences were limited.  

Now:  

  • Exposure to corporate criminal prosecution.  
  • Potential for unlimited fines.  
  • Risk of asset confiscation and public conviction.  

 

Just as importantly, the threshold for liability is lower.  

Previously, prosecutors needed to prove that senior leadership (the “directing mind”) knew about or intended the harm.  

Now, liability can arise from a single senior manager facilitating, enabling, or ignoring exploitation within their role . 

If the underlying criminal offence is proven, the company can be held responsible.  

A crucial point: there is no automatic defence 

One of the most surprising aspects of this change is what it doesn’t include.  

Unlike laws covering bribery or failure to prevent fraud,  
Section 250 does not provide a statutory defence for having ‘reasonable procedures’ in place.  

This means:  

  • Strong policies alone will not protect an organisation from liability  
  • Even robust due diligence frameworks are not a legal shield  

However, this work is still critically important.  

  • Good systems, oversight, and culture may help demonstrate that prosecution is not in the public interest  
  • But they do not remove the legal risk altogether  

 

What should organisations take away from this? 

This change signals a broader shift in expectations.  

Modern slavery is no longer just about what you say in your statement – it’s about what is actually happening across your operations and supply chains.  

Key takeaways  

Modern slavery risk is now a core criminal risk – not just a compliance exercise.  

Organisations should be thinking about:  

  • How decisions are made across operations and procurement.
  • Where authority sits in practice (not just on paper).  
  • Whether concerns can be raised and acted on safely. 
  • How effectively risks are identified and addressed in real time . 

 

Final thoughts  

This legal development reinforces something survivors and frontline organisations have long known – exploitation often happens in operational blind spots, not boardrooms . 

Section 250 brings those realities into sharper legal focus.  

If your organisation is reviewing its approach to modern slavery, Unseen can help you understand risk, strengthen practice, and focus on meaningful action.  

Note: This brief overview from Unseen is aimed at helping you understand recent legal changes. Unseen however is not a legal entity, and this should not be taken as legal advice.  

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Justine Currell

As I came to understand more about the issue, including through a visit to an Unseen safehouse, I knew I needed to do more to stop this abuse and exploitation.

For the last five years of my Civil Service career, I was the Modern Slavery Senior Policy Advisor in the Home Office and led on development of the Modern Slavery Act, including the transparency in supply chains provision and business guidance.

I joined Unseen to lead the development of the Modern Slavery & Exploitation Helpline, and Unseen’s work with businesses. I am regularly called upon to present at national and international conferences and use my experience of working with Ministers to influence other governments internationally to take action to address modern slavery and, in particular, business supply chain issues.

In my spare time I enjoy keeping fit, music, reading and travelling.

Andrew Wallis

What ultimately compelled me to act was a report on how people from Eastern Europe were being trafficked through Bristol airport to the USA. Kate Garbers, who went on to be an Unseen Director, and I wrote to all the city councillors, MPs and the Police Chief Constable challenging them on the issue. The challenge came back to us: this city needs safe housing for trafficked women. And so Unseen began.

But we never wanted Unseen to be just about safe housing. We wanted to end slavery once and for all, and that remains our driving focus.

I chaired the working group for the Centre for Social Justice’s landmark report “It Happens Here: Equipping the United Kingdom to Fight Modern Slavery”. This is now acknowledged as the catalyst behind the UK’s Modern Slavery Act of 2015. It was a great honour to be awarded an OBE in the Queen’s Birthday Honours that year. On the other hand, I’ve also been described as “the loveliest disrupter you could ever hope to meet”.

This job has taken me from building flat-pack furniture for safehouses, to working with businesses to address slavery in supply chains, to delivering training, raising awareness and advising governments around the world.

When not at work, I enjoy travelling, spending time with my dog Harley, cooking, supporting Liverpool and Yorkshire CC, music (I’m a former DJ) and endurance events such as the Three Peaks Challenge and Tribe Freedom Runs – which I vow never to do again. Until the next time.