Modern slavery due diligence software helps an Australian organisation map suppliers across tiers, screen them for modern slavery risk, monitor changes and keep an evidence trail. It matters because reform is moving the Modern Slavery Act 2018 from annual disclosure towards risk-based due diligence with penalties, which cannot be run from spreadsheets across a large supplier base.
Key takeaways
- Entities with annual consolidated revenue of at least $100 million that carry on business in Australia must lodge an annual modern slavery statement.
- The statutory review and the Anti-Slavery Commissioner have pushed for mandatory, risk-based due diligence and penalties. Final detail is still being worked through.
- Suppliers below the threshold feel it second-hand, because large customers doing real due diligence ask their suppliers for evidence.
- A modern slavery due diligence platform earns its place in four jobs: supplier mapping, risk screening, continuous monitoring and evidence.
- AI carries volume and continuity. People still make the risk judgements and decide on remediation.
From a statement to a standard of care
For most entities captured by it, the Modern Slavery Act 2018 has felt like an annual writing task. An entity above the revenue threshold prepares a statement each financial year describing risks in its operations and supply chains and the steps taken to assess and address them, against the Act's mandatory criteria, and lodges it on the public register. Around 3,000 entities report this way.
That settled state is ending. The 2023 statutory review of the Act and Australia's Anti-Slavery Commissioner have both pushed towards stronger obligations, and the government has signalled it will strengthen the framework. Proposals discussed include civil penalties for non-compliance, a mandatory risk-based due diligence obligation, a failure-to-prevent style offence for large organisations with a reasonable steps defence, and a mechanism to declare high-risk products, services or industries.
The direction is from disclosure to action. For an operations, procurement or compliance lead at an importer, manufacturer or wholesaler, that is a material change. A statement can be written by two people once a year. Genuine due diligence is a continuous data exercise across the whole supplier base, provable on demand.
Are you in scope, and how deep does it go?
A business can easily sit above the $100 million line, particularly an importer, distributor or manufacturer where revenue is high relative to headcount. Due diligence also pushes responsibility down the chain, so suppliers to reporting entities feel it through customer questionnaires and contract clauses.
Where does your business sit?
- Revenue at or above 100 million dollarsA reporting entity, due diligence duties are likely
- You supply large reporting entitiesExpect due diligence requests to intensify
- You import goods from higher-risk regions or sectorsElevated risk, prioritise supplier mapping
- Domestic services with a simple supply chainLower exposure, but monitor as rules firm up
The affected population is much larger than the reporting entities. Getting scope right means knowing how far down and across your supply chain a credible process must reach, and how much of that evidence your customers will start to demand.
Why reform breaks the old approach
A statement can be written top down: gather what you know, describe the supply chain broadly, list the policies. Due diligence works bottom up. You need to know who your suppliers are beyond the first tier, assess each against real indicators, act proportionately where risk is found and keep it current.
| Annual Statement | Continuous Due Diligence | Impact | |
|---|---|---|---|
| Supplier visibility | First tier, described broadly | Mapped across tiers | Deeper |
| Risk assessment | General narrative | Screened against real indicators | Evidenced |
| Cadence | Once a year | Ongoing monitoring | Continuous |
| Response to risk | Optional, described | Proportionate action expected | Active |
| Evidence for a regulator | The statement itself | A documented audit trail | Provable |
A large business may work with hundreds or thousands of suppliers. Assessing that network in spreadsheets and email threads was never feasible, which is partly why disclosure tolerated generalisation. Once penalties attach, the gap between a narrative and an evidenced process becomes legal exposure.
What should modern slavery due diligence software do?
AI does not discharge the obligation and does not replace the judgement the law expects. It carries the volume and continuity so accountable people spend time on decisions and remediation. A modern slavery due diligence platform, whether bought or built, should do four things.
1. Supplier mapping and tiering. Supplier information is usually scattered across procurement, accounts payable, contracts and inboxes. AI can consolidate it, extract supplier relationships from documents and build the tiered map due diligence depends on. It is the same discipline as using AI to extract key terms from contracts.
2. Risk screening. Risk concentrates by geography, sector, type of work and the length and opacity of the chain. Screening against these indicators and public risk information focuses limited human effort where it matters.
- MapConsolidate suppliers across tiers
- ScreenRank by geography, sector and risk indicators
- AssessDeeper review of higher-risk suppliers
- EvidenceRecord findings and actions for the register
3. Continuous monitoring. New suppliers are added, circumstances change and public signals shift. Automated monitoring keeps the picture current and flags material changes for a person to review. See our guide to automated compliance reporting for the same shift elsewhere.
4. Evidence and statement drafting. Automated logging of what was assessed, found and done produces the audit trail a reasonable steps defence relies on. The annual statement then summarises a real process.
- Manual: mapping a large supplier base by handWeeks, incomplete
- Manual: assessing every supplier equallyEffort spread too thin
- Automated: consolidated map and risk rankingFocused on real risk
- Automated: continuous monitoring and audit trailRuns in the background
Buy a platform or build on your own systems?
Specialist modern slavery platforms suit organisations that want a ready questionnaire library and supplier portal. Building on your existing ERP and procurement data suits organisations whose supplier records are already structured and who want the evidence to sit with their other compliance data. Many end up with both: a platform for supplier engagement and an integration layer that keeps supplier master data, spend and risk scores aligned.
What does "reasonable steps" look like in practice?
A reasonable steps defence does not demand perfection or the elimination of all risk from a chain you do not control. It demands a genuine, proportionate, documented process you can put in front of a regulator.
For example, a 300-staff importer sourcing from several countries cannot audit every factory in every tier, and is not expected to. A reasonable position looks like:
- A supplier map that reaches beyond tier one where risk sits.
- Risk assessment that concentrates scrutiny on higher-risk sourcing.
- Evidence of action where risk was found.
- Monitoring that keeps the picture current.
None of that needs a large compliance department. All of it needs structured data and a repeatable workflow. The organisations that struggle most are those with the least structured data about their supply chains, not those with the most complex ones.
The trajectory, and what it rewards
- 2018Disclosure regimeAnnual modern slavery statements for entities over the revenue threshold
- 2023 to 2024Review and CommissionerStatutory review recommendations and an Anti-Slavery Commissioner pressing for due diligence
- NowReform signalledGovernment signals stronger obligations, including penalties and due diligence
- AheadConsultation and detailScope of mandatory due diligence and penalty settings worked through
Penalty levels and the exact scope of any duty are still being worked through, so do not treat any figure or start date as settled. The direction is settled, and it favours organisations that build capability early.
Modern slavery sits alongside other evidence-based obligations, including climate disclosure under AASB S2. We built Carbonly.ai, our own ESG and emissions automation product, on the same pattern: pull structured evidence out of messy supplier documents and keep an audit trail. Each new obligation is cheaper once that data plumbing exists.
What to do now
- Visibility. Know who your suppliers are, across tiers, in structured form.
- Risk focus. Rank the supplier base so attention goes to genuine risk.
- Evidence. Log what you assess and do, so reasonable steps is demonstrable.
The same supplier map also strengthens procurement, resilience and quality, which connects to AI use cases in Australian manufacturing and order automation for wholesale distributors.
How Solve8 can help
We connect procurement, accounts payable and contract data into a supplier map with risk screening, monitoring and an evidence trail, running on your infrastructure in Australia with a person approving every risk decision. See our process automation and system integration services, or talk to our team.
This article is general information, not legal or compliance advice. Confirm your obligations against Australian Government and Anti-Slavery Commissioner guidance and qualified advice.
