Comparison table of Modern Slavery Acts and CSRD S2 reporting. Exchange rates calculated February 19, 2026
| Dimension | UK MSA | Aus MSA | CSRD |
|---|---|---|---|
| Scope | Companies with a turnover of £36m GBP | Companies with a turnover of $100 (£52m) million AUD | Publicly listed EU entities with over €50 (£44) million euros turnover and 250 employees (Wave 1); Companies with a turnover of €450 (£390m) million and 1,000 employees (Wave 2+) |
| Reporting requirements | Business structure; modern slavery policies; supply chain due diligence policies for modern slavery; identified modern slavery risks and actions taken; how the business has ensured modern slavery is not occurring in the business’s supply chain; training provided to staff on modern slavery | Structure, operations and supply chain; identified modern slavery risks; actions taken to assess and address modern slavery risks; how reporting organisations are assessing the effectiveness of these actions; consultation efforts with other organisations they own or control for the above | Impact, risk and opportunity identification and prioritisation process (IROs); policies related to value chain workers (S2-1); engagement with value chain workers on adverse human rights (S2-2); remediation mechanisms and channels available to value chain workers to raise concerns (S2-3); actions taken to address material impacts on value chain workers, and their effectiveness (S2-4); targets associated with managing material negative impacts and risks concerning workers in the value chain (S2-5) |
| Penalties | No direct penalties | Not yet established | Financial penalties and potential sanctions exist, but are set at the discretion of each member state |
| Dimension | Aus | ||
|---|---|---|---|
| Scope | Companies with a turnover of £36m | Companies with a turnover of $100 (£52m) million | Publicly listed |
| Reporting requirements | Business structure; modern slavery policies; supply chain due diligence policies for modern slavery; identified modern slavery risks and actions taken; how the business has ensured modern slavery is not occurring in the business’s supply chain; training provided to staff on modern slavery | Structure, operations and supply chain; identified modern slavery risks; actions taken to assess and address modern slavery risks; how reporting organisations are assessing the effectiveness of these actions; consultation efforts with other organisations they own or control for the above | Impact, risk and opportunity identification and prioritisation process (IROs); policies related to value chain workers (S2-1); engagement with value chain workers on adverse human rights (S2-2); remediation mechanisms and channels available to value chain workers to raise concerns (S2-3); actions taken to address material impacts on value chain workers, and their effectiveness (S2-4); targets associated with managing material negative impacts and risks concerning workers in the value chain (S2-5) |
| Penalties | No direct penalties | Not yet established | Financial penalties and potential sanctions exist, but are set at the discretion of each member state |
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