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Posted by Brad Leonard
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21 Oct, 2026
AUSTRALIA's approach to modern slavery is entering a significant period of reform, with proposed legislative changes placing greater emphasis on corporate accountability and the identification of risks throughout international supply chains.
On 15 October 2026, Australian Anti-Slavery Commissioner Chris Evans released Impact through action: A framework for modern slavery reform, recommending a shift beyond reporting obligations towards mandatory, risk-based due diligence.
Australia's Modern Slavery Act 2018 (Cth) currently requires entities with annual consolidated revenue of at least $100 million to report annually on modern slavery risks within their operations and supply chains.
The Commissioner proposes a broader framework incorporating mandatory due diligence, stronger regulatory oversight, a carefully designed criminal offence targeting serious corporate conduct, improved reporting and enhanced access to remedies for victims.
These recommendations build on the Australian government's July 2026 proposal to introduce a corporate criminal offence for failing to prevent modern slavery in supply chains.
IFCBAA's ongoing industry engagement
Recognising the importance of modern slavery awareness across international trade, IFCBAA has continued to engage with government and industry to promote greater understanding of supply chain risks and responsible business practices.
On 22 April 2026, IFCBAA hosted a webinar featuring the Office of the Australian Anti-Slavery Commissioner, providing members with an opportunity to engage directly with the Office and develop their understanding of Australia's modern slavery framework. This initiative complemented modern slavery awareness sessions delivered through IFCBAA's Continuing Professional Development (CPD) events and coverage in Association publications.
These initiatives reflect IFCBAA's commitment to keeping members informed about emerging regulatory expectations, including those extending into broader environmental, social and governance (ESG) areas, while supporting practical approaches to compliance.
Implications for international freight and logistics
Modern slavery risks can arise across complex international supply chains, including manufacturing, agriculture, warehousing, transport and subcontracted services.
Effective management of modern slavery risks across international supply chains requires greater visibility of suppliers, targeted risk assessments and ongoing engagement with supply chain partners, rather than relying solely on documentation and compliance reporting.
For licensed customs brokers and freight forwarders, additional expectations may emerge through customer due diligence, procurement requirements and contractual arrangements, even where businesses fall below Australia's statutory reporting threshold.
Importantly, the Commissioner recognises that obligations must remain proportionate and should not require businesses to possess complete information about every supply chain tier.
The report also identifies opportunities to explore how customs data could assist in identifying higher-risk supply chains.
Balancing accountability with practical implementation
The Commissioner’s new paper, Getting the Balance Right: Modern Slavery Due Diligence and SMEs, highlights the need to strengthen supply chain accountability without placing unnecessary compliance burdens on smaller businesses.
It recommends proportionate, risk-based due diligence, greater consistency in supplier information requests and improved industry collaboration.
For freight forwarders and licensed customs brokers, this is particularly relevant where customers seek information beyond their direct knowledge or control.
IFCBAA supports stronger modern slavery protections but believes reforms must recognise the differing roles and capabilities of industry participants, avoiding unnecessary duplication while delivering meaningful improvements in supply chain integrity.
