Chartered Accountants Australia and New Zealand (CA ANZ) has submitted its recommendations to the Attorney-General’s Department on proposed reforms to the Modern Slavery Act 2018 (Cth). Drawing on its experience as both a reporting entity and an advocate for members across diverse sectors, CA ANZ supports strengthening the Act but stresses that reforms must be practical, proportionate and supported by clear guidance.

Support for reform, with a focus on proportionality

CA ANZ welcomes changes to make the Act more effective but highlights that new obligations must be matched with clear expectations. This is especially important for entities new to modern slavery reporting, where requirements often demand significant judgement. The submission emphasises proportionality—ensuring obligations reflect an entity’s risk, size, resources and operating context—to keep compliance practical and meaningful.

Concerns for smaller entities

A key concern is the potential burden on smaller reporting entities, particularly those near the $100 million consolidated revenue threshold. These organisations may have limited influence over complex global supply chains. CA ANZ warns that expanding obligations could increase compliance costs without significantly improving modern slavery risk management.

Due diligence design must fit all sizes

The current due diligence (DD) model appears tailored for large, mature organisations with specialist teams. For smaller entities, DD would be a major shift, often without in-house human rights expertise. CA ANZ calls for government guidance on relevant risks by sector, what “reasonable and proportionate” DD looks like, and how expectations should scale. The submission suggests either targeting DD requirements to larger entities or building proportionality into the DD framework.

Capacity-building and practical tools

CA ANZ argues that capacity-building should be a core pillar of the regime. Practical guidance and tools—such as those used in the NSW modern slavery framework—can help entities prioritise risks. The submission points to the phased rollout of climate disclosure requirements and AUSTRAC’s targeted toolkits as models for effective support.

High-risk declarations and collaboration

CA ANZ supports government-issued declarations of high-risk sectors, geographies or supply chain characteristics. These would help entities focus their efforts, improve reporting consistency and reduce generic disclosures. The submission also encourages collaboration across supply chains to avoid duplication and enable deeper engagement where risks are systemic.

Managing small business impacts and regulatory overlap

While the Act targets large entities, CA ANZ notes the flow-on effects for small and medium businesses, which often face multiple information requests. Solutions such as centralised self-assessment, standard templates and “one-to-many” reporting could reduce this burden. The submission also calls for reform timing to consider other regulatory changes, such as climate disclosures and workplace reforms, to avoid overwhelming businesses.

Balanced enforcement and ongoing engagement

CA ANZ supports a graduated approach to enforcement, starting with education and constructive engagement, escalating to warnings and proportionate penalties for repeated or serious non-compliance. The submission reiterates the need for capacity-building, risk prioritisation, collaboration and credible enforcement to ensure the Act delivers real-world impact.

CA ANZ remains committed to supporting members and engaging with government to strengthen modern slavery risk management across Australia.