The debate on corporate responsibility in global supply chains in Australia has reached a decisive stage in the auspices of From Reporting to Accountability. It is the push by the Anti-Slavery Commissioner, Chris Evans to ensure that the country changes the current approach of its Modern Slavery Act by its transparency model to an enforceable due diligence approach. The proposed recalibration comes at a time when the international focus on the risks of forced labor is growing and when the key trading partners have already left the voluntary disclosure regimes.
With the Modern Slavery Act becoming law in Australia in 2018, big companies are obligated to release yearly reports presenting the information on the exposure to the risks of forced labor. Though there are over 2,000 entities which have reported, critics believe that the framework does not have enforcement measures which have created unequal standards and low deterrence. The January 2026 reform paper by Evans argues that disclosure is not a material reduction of exploitation, especially in high-risk industries such as textiles, agriculture, and seafood.
Structural Gaps in the Existing Framework
The present Act is indicative of a time when transparency was seen as a force of change in the company. Nevertheless, the international regulatory environment has changed a great deal, revealing the structural deficiency in the model of Australia.
Transparency Without Enforcement
In the 2018 law, firms whose annual revenue surpasses the limit of AU 100 million will have to submit statements of risks and mitigation plans. However, the Act does not bring any financial punishment in case of poor reporting and does not force substantial action in case of risks being detected.
At one point Evans has made a public argument that a large number of statements are policy affirmation and not operational commitment. The Attorney-General Department reviews performed up to 2025 reported that there was a high degree of variability in the quality of reporting. Others gave elaborate mapping and remediation of supply chains, whereas others were able to declare brief principles in a brief statement that did not have practical thresholds.
Competitive distortions have also been caused by lack of enforcement. Companies that spend a lot of money on compliance incur more costs as compared to those that use generic disclosures. This imbalance has increased the calls to reform by the ethical investors and civil society organizations that want to have consistent standards.
Domestic and International Exposure
In 2023, the Global Slavery Index estimated that in Australia, there were some 41,000 people who could be living in conditions of modern slavery, such as forced labor and debt bondage. Although there is no easy way of measuring domestic prevalence, parliamentary hearings in 2025 highlighted the weak points in agriculture, construction, and migrant labor channels.
The exposure is even more international. Australia receives the large amounts of imports of goods that the global watchdogs have raised red flags in terms of forced labor. In 2026, big box retailers were sued by people alleging connection to Xinjiang supply chains, which increased people’s awareness. Even though the companies in question disclaim any accusations and claim to do everything to comply, the cases show reputational and legal risks associated with global sourcing.
Evans’ Reform Blueprint
The reform agenda by the Commissioner is meant to transform the Act as a reporting tool into a preventive compliance regime. It is focused on risk-based due diligence which is proportional and supported by the possible ramifications of failure to comply.
Mandatory Due Diligence Obligations
Evans suggests the systematic risk evaluation undertaken by companies, the mitigation strategies, and remediation reports. More importantly, the requirement would not be a disclosure but rather a manifest action. Entities would be required to incorporate due diligence in the form of governance structures, supplier contracts and procurement practices.
This would bring Australia closer to the 2025 Corporate Sustainability Due Diligence Directive of the European Union that requires risk management throughout the value chains and permits imposing serious fines, which depend on turnover. Similar structures have been followed in Canada and Germany. Evans has warned that the possibility of not modernizing may see Australia falling behind in terms of new trade demands, and this may have an impact on market access.
Regulatory supervision through investigative authority is also in the consideration of the reform blueprint. Although the exact model of implementation is yet to be consulted, proposals have been put across civil fines and naming of those who do not comply with the law persistently.
High-Risk Sector Declarations
The other foundation of the proposal is the establishment of high risk declarations. According to this mechanism, the Commissioner might declare certain products, regions or industries as having to be subjected to extra scrutiny.
Such as, cotton associated with Xinjiang or some distant water fishing activity might provoke the due diligence procedures. The firms that engaged in or source in the reported industries would be required to show active risk mitigation instead of taking the help solely of the supplier assurance.
Evans has termed this targeted model as pragmatic and proportionate model and argues that it provides clarity to the businesses whilst giving more importance to the protection of the workers. Regulators are able to invest in areas of recorded risk thus preventing blanket prohibitions on less risky areas.
Stakeholder and Political Dynamics
The wave of reform is an expression of a legal, business, and geopolitical force. Nonetheless, the road to legislative transformation is still not easy.
Business Community Responses
Large retailers and manufacturers have accepted the necessity of supply chain integrity but have recommended cautious calibration. The warning of industry groups is that over strict demands might overstretch smaller suppliers and lead to disruption in the procurement processes.
Meanwhile, forced labor risk is becoming a material governance issue in the eyes of institutional investors. The Australian superannuation funds have embraced environmental, social, and governance framework in 2025 and raised the human rights due diligence to a level of capital allocation decision.
The question on whether there is a need to conduct due diligence has thus taken a back seat to how it should be formulated. Businesses want honesty lapses and good-faith harbors.
Government Consultation and Legislative Path
In the year 2025, the Department of Attorney-General gave extensive consultations in a bid to monitor the effectiveness of the Act. The civil society submissions highlighted that the reputation-based incentives are not enough to curb harm.
As a government, business and advocacy network coordinating body appointed in late 2024, Evans as the first federal Anti-Slavery Commissioner of Australia has located his office as a coordinating body. His reform paper incorporates the 2025 stakeholder roundtable feedback and overseas legislation analysis.
Change seems to be politically appetitive. The resulting cross-party recognition of international alignment pressures has opened up the way to make changes in legislation, but fiscal and regulatory impact assessment is pending.
Global Regulatory Convergence
The debate on reform in Australia is not in a vacuum. The global regulatory landscape has been changing towards binding corporate accountability, which increases comparative pressure.
Trade and Market Implications
The Uyghur Forced Labor Prevention Act by the United States assumes that the goods associated with Xinjiang cannot be imported until the importers can prove otherwise. The forced labor importation ban system of the European Union, which will become effective in 2025, is also a system which enables the customs to block suspect products.
These are steps which have transformed international standards of compliance. To gain entry into European or North American markets the Australian exporters are forced to prove traceability and risk management ability in a greater number. Australian companies will risk overlapping compliance expenses in the overseas markets without similar domestic standards.
Evans has framed reform as a competitiveness issue as much as a moral imperative. Aligning domestic law with international due diligence requirements could streamline compliance for multinational enterprises operating across jurisdictions.
Enforcement Capacity and Implementation Challenges
Introducing mandatory obligations will necessitate enhanced regulatory infrastructure. Analysts note that effective enforcement requires trained investigators, data systems, and inter-agency coordination.
The reform paper acknowledges these capacity constraints. Funding allocations and institutional design will determine whether new obligations translate into tangible outcomes. Without robust oversight, critics warn, due diligence could devolve into procedural formalities.
Additionally, measuring impact presents methodological challenges. Establishing standardized metrics for remediation and risk reduction is complex, particularly in opaque supply chains spanning multiple jurisdictions.
Shifting Norms of Corporate Responsibility
The phrase From Reporting to Accountability captures a broader evolution in corporate governance philosophy. Transparency once served as a proxy for responsibility, based on the assumption that public disclosure would incentivize ethical conduct. Yet experience across multiple jurisdictions suggests disclosure without consequence has limited transformative power.
Australia now faces a decision point. If Parliament adopts a due diligence model with meaningful enforcement, the Modern Slavery Act could become a more substantive instrument of risk prevention. If reforms stall or remain diluted, the country may continue to rely on reputational pressure in an era defined by regulatory convergence.
The coming months will reveal whether legislative momentum translates into structural change. As global supply chains grow more complex and geopolitical scrutiny intensifies, the test for Australia lies not merely in publishing statements but in demonstrating whether law can reshape commercial behavior at scale.