Strengthening the Modern Slavery Act 2018 (Cth)

Closes 1 Sep 2025

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PART C – Joint reporting

Section 14 of the Modern Slavery Act permits entities to submit a statement on behalf of one or more reporting entities. All reporting entities under the Modern Slavery Act are eligible to jointly report and there is no limit on how many entities a joint statement can cover. Entities that provide a joint statement may be part of the same corporate group or may be unrelated entities. The review highlighted that while flexibility of the joint statement process was generally supported, some feedback pointed to difficulties encountered in joint reporting. This included:

  • dormant entities within a complex group structure may be required to report separately
  • separate identification should not be required for each subsidiary within a group structure that meets the consolidated revenue threshold
  • sign-off requirements can be complex for joint statements.

To address challenges with joint reporting processes, the department proposes replacing current joint reporting procedures with a system for corporate group reporting. Under this option:

  • One statement would be submitted by the highest entity (parent entity) within a consolidated corporate group, on behalf of all entities within that group.
  • The highest entity would be required to report on all owned and controlled entities (even if they do not meet the reporting threshold), ensuring that transparency relating to additional entities within the group structure is adequately covered.
    • This is consistent with current requirements of the Modern Slavery Act (paragraphs 16(1)(c) and (d)) which already require a reporting entity to report on the risks of modern slavery practices in the operations and supply chains of the reporting entity, and any entities that the reporting entity owns or controls; and to describe the actions taken by the reporting entity and any entity that the reporting entity owns or controls.
  • The highest entity would identify as a reporting entity, on behalf of the corporate group. The highest entity would submit the modern slavery statement on behalf of all entities within that consolidated group. Any compliance action would be taken against the highest entity.
  • Entities may apply to the regulator to alter the default reporting arrangements by:
    • having another entity report on their behalf (nominee reporting entity), or 
    • having certain entities within the group report individually (subsidiary reporting entity).

For further information on the options to change joint reporting procedures refer to Part C of the consultation paper.

Are there any additional difficulties encountered with joint reporting under the Modern Slavery Act?

(Please select one)

Does corporate group reporting adequately resolve challenges experienced by reporting entities with the current joint reporting model?

(Please select one)

Are there any new challenges that may result from replacing the current joint reporting process with a corporate group reporting model (with exemptions)?

(Please select one)

Should a corporate group reporting model be adopted, do the proposed exemptions (via application to the regulator) for subsidiary and nominee reporting entities provide appropriate and sufficient accommodations for different business structures?

(Please select one)

Should a corporate group reporting model be adopted, should any additional exemptions be considered to alter the default reporting arrangements of corporate group reporting?

(Please select one)

Are there alternative mechanisms to improve or amend the current joint reporting processes?

(Please select one)