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Time’s up on ticking boxes: how housing associations are expected to report on modern slavery
The 2025 Modern Slavery Act transparency guidance raises the bar on corporate reporting. Housing associations need to understand the new expectations, writes Francesca Lee, chief executive and founder of Social Value Architect
Francesca Lee is chief executive and founder of SocialValueArchitect
The 2025 Modern Slavery Act transparency guidance raises the bar on corporate reporting, writes Francesca Lee, founder of Social Value Architect #UKhousingThe UK social housing sector has long had community and human dignity at its heart. But if we’re serious about protecting people – residents, workers and the unseen hands behind our supply chains – then we can no longer treat modern slavery reporting as a once-a-year compliance exercise.
The 2025 Modern Slavery Act transparency guidance raises the bar on corporate reporting. Businesses above the £36m threshold are now expected to disclose real data, not just vague policies. With a new emphasis on continuous improvement, incident disclosure and multi-tier accountability, the days of template-driven modern slavery statements are numbered. Whether you are a developer, fund or investor in the social housing sector, this is a moment to rethink how you track, remediate and report on ethical labour risk.
Compliance still matters – but now, so does credibility.
The corporate modern slavery statement was never supposed to be a PR exercise. Yet, for many UK businesses, that’s precisely what it has become: templated, vague and quietly parked on the website once a year.
That approach won’t cut it anymore.
With the release of the 2025 guidance, the dial has shifted. The pressure is on – not just to tick the box, but to prove that your business is actually doing the work.
The original intent of Section 54 of the Modern Slavery Act 2015 was clear: to shine a light on what businesses are doing to tackle the risk of modern slavery across their operations and supply chains. If your company meets the threshold – £36m turnover and doing business in the UK – you must publish a public statement each financial year.
“The corporate modern slavery statement was never supposed to be a PR exercise. Yet, for many UK businesses, that’s precisely what it has become: templated, vague and quietly parked on the website once a year”
Let’s be honest: until now, the bar has been low. Many organisations offer little more than a general nod to due diligence, peppered with vague aspirations. A few even admit they’ve taken no steps at all, because, legally, that’s still allowed.
However, with the new guidance, that era of minimalism is officially over.
One of the most striking developments is the introduction of the term “modern slavery disclosures”. While not a statutory phrase, its inclusion signals a pivot towards a more rigorous, report-like expectation – one more aligned with broader ESG and sustainability frameworks, like the EU’s Corporate Sustainability Reporting Directive.
This is not about perfection. It’s about progress. The guidance emphasises continuous improvement, expecting companies to demonstrate how their efforts are evolving year on year, not just repeated.
Let’s be clear: complexity in supply chains is not an excuse. Whether you’re a holding company, or part of a sprawling multinational, the expectation is now explicit. If one part of your group meets the threshold, transparency must extend across the entire relevant structure – and the public deserves to know who and what is covered. Whether you are part of a housing group or joint venture, if any part of your entity meets the £36m threshold, then your obligations now apply to the whole group. Transparency must follow the money and the risk.
This also applies to funders and institutional investors supporting housing development. If your name is on the project, your practices are under the microscope.
The old excuse – “our supply chain is too complex” – won’t cut it anymore.
“The guidance emphasises continuous improvement, expecting companies to demonstrate how their efforts are evolving year on year, not just repeated”
The social housing sector isn’t just about bricks and mortar. It’s about safe, dignified living. That means holding ourselves and our partners to higher ethical standards. Failure to do so has real consequences:
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Procurement teams are tightening ESG requirements
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Investors are evaluating ethical performance
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Insurers are assessing human rights risk exposure
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Tenants are demanding fairness and justice at every level
The updated guidance lays out six recommended areas of disclosure, ranging from organisational structure and supply chains, to policies, risk assessments, due diligence, training and monitoring. But this time, it introduces graduated expectations.
If your company is reporting for the first time, you’re expected to start with foundational information (Level 1). As you move into repeated reporting cycles, the level of detail and accountability must increase (Level 2). You may now consider the following:
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Include evidence of progress year on year
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Identify where interventions have worked and where they haven’t
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Explain how you plan to improve further
In practical terms, you need to be able to explain not just what you’re doing, but how it’s working, where you’ve fallen short, and what you’re doing to improve. For housing providers with long-standing supply chains in construction, maintenance and social care, this will require deeper engagement and better data-collection, not just from tier 1 suppliers, but from the sub-contractors and agencies they rely on.
Perhaps the most radical change is the expectation that businesses disclose actual incidents of modern slavery in their operations or supply chains, along with the remediation taken.
That’s a major cultural shift. Until now, many organisations avoided disclosures for fear of reputational damage. That’s changing. In fact, acknowledging and acting on real issues are becoming the hallmark of ethical leadership. A clean sheet doesn’t necessarily mean ethical operations. It may just mean you’re not looking hard enough.
The revised guidance reminds us that the modern slavery statement is not a guarantee of perfection – it’s a signal of intent and action. You’re not expected to eliminate modern slavery overnight, but you are expected to be honest about where you are, where the risks lie, and what you’re doing about them.
Ticking the box won’t be enough this year. The public, investors, regulators and your own employees are asking tougher questions. And now, the guidelines demand better answers.
The message in 2025 is clear: it’s not about being perfect. It’s about being honest, responsive and committed. You can no longer reproduce your modern slavery statement with just a few tweaks here and there. You actually have to put some thought into each statement every year, like you do for your annual reports. You have to show how you are improving your processes and disclose any uncomfortable findings honestly.
Your modern slavery statement will now be scrutinised by your buyers, clients, investors, public authorities and even your insurers where ethical labour practices and responsible sourcing matter.
It’s no longer just the responsibility of your CSR Manager. It is now a governance responsibility of your board.
Francesca Lee, chief executive and founder, Social Value Architect
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