Australian Modern Slavery Act is Moving from Transparency towards Accountability: Reasonable Steps Now Need More Than Reasonable Intentions

In 2018, Intertek launched Inlight as an end-to-end supply chain risk-management solution. That was the same year Australia passed the Commonwealth Modern Slavery Act. While much of the market prepared to publish statements, Inlight was built around a harder question: what will a business actually do after it identifies risk?

Australia is moving from transparency towards accountability

On 16 July 2026, the Australian Government announced its intention to introduce a criminal offence for companies with annual consolidated revenue above A$100 million that fail to prevent modern slavery in their supply chains. The proposed model would include a defence where a company can demonstrate that it took reasonable steps to prevent modern slavery. The Government also intends to add civil penalties and associated enforcement powers for non-compliance with existing Modern Slavery Act obligations.

These are proposed reforms, not yet enacted law. The detailed offence, enforcement model, meaning of reasonable steps and commencement timing will be shaped through consultation and legislation. But the direction is unmistakable: modern slavery governance is moving beyond the quality of an annual statement towards the quality of the system, decisions and evidence behind it.

A modern slavery statement can describe a programme. It cannot substitute for one.

The announcement also sits within a broader reform programme that has already examined stronger reporting criteria, corporate group reporting, compliance and enforcement tools, and greater attention to grievance mechanisms, remediation, governance, training and effectiveness. Those measures remain at different stages of development, but together they point to the same practical expectation: businesses should be able to show what they knew, how they prioritised risk, what they did, whether their information was reliable and what changed as a result.

Inlight was built for action before the Act commenced

Intertek launched Inlight Network in April 2018 as an end-to-end risk-management solution combining supplier profiles, self-assessment, verification, audit history, data insights and continuous improvement. The launch model was supported by local compliance experts in more than 65 countries. Australia’s Modern Slavery Act then commenced on 1 January 2019.

Inlight has therefore been ready and waiting for the market to make the same shift: from disclosure to due diligence; from supplier declarations to verified evidence; and from activity counts to demonstrated prevention, corrective action and improvement.

That is also why Inlight should not be understood as a stand-alone software platform or a digital questionnaire tool. It brings people, process and technology together. The technology connects the evidence. The process determines proportionate action. The people—local programme teams, technical experts, verifiers and auditors—turn information into decisions and improvement.

What reasonable steps look like in a working due diligence system

No final Australian statutory test for reasonable steps has been enacted. It would be wrong to present a product workflow as the legal definition. However, the OECD Due Diligence Guidance and the UN Guiding Principles already provide a well-established model for responsible business conduct: embed responsible conduct into governance; identify and assess actual and potential impacts; cease, prevent or mitigate harm; track implementation and results; communicate; and provide for or cooperate in remediation where appropriate.

Inlight operationalises that continuous cycle across the supply chain. It creates one connected route from inherent risk to residual risk, from supplier response to verified result, and from capacity building to audit, corrective action, remediation and measurable improvement.

This is what treating modern slavery as a genuine duty of care looks like in practice: an ongoing, proportionate process focused on risks and outcomes for people, rather than an annual writing exercise.

1. Create supplier visibility

Due diligence begins with usable data. Inlight supports supplier onboarding, data cleansing, classification and supply chain mapping, including supplier tiers and the attributes needed for meaningful risk analysis. This matters because a spend list alone cannot reveal where vulnerable workers, labour providers, high-risk commodities or less visible tiers may sit.

2. Prioritise inherent risk intelligently

Inlight combines external country-risk sources with business-specific factors such as sector or commodity, supplier activity, spend, strategic or single-source dependency, the nature of the business relationship, brand exposure and custom risk attributes. The external data can draw on sources including the World Bank Governance Indicators, UN Human Development Index, Transparency International Corruption Perceptions Index, US State Department Trafficking in Persons Report and Sustainable Development Report. Organisations can configure weightings to reflect their operating model. The result is a defensible way to focus finite resources on the most severe and likely risks to people, rather than treating every supplier as equal or allowing spend to become the default proxy for human-rights risk.

3. Assess controls and build supplier capability

Targeted self-assessment questionnaires can examine modern slavery, labour and human rights practices, operational controls and supply chain management. They can be standardised or customised to the organisation, sector and supplier group. Crucially, they are designed to do more than collect a yes-or-no declaration. Questions, evidence requests and guidance help suppliers understand what good practice looks like while giving the buying organisation a clearer view of control maturity and residual risk.

4. Verify what matters

Self-reporting is useful, but unverified answers can create false confidence. Inlight supports expert desktop verification of supplier responses and evidence, with escalation to remote assessment or on-site audit where risk warrants deeper examination. That verification step tests whether the claimed policy, process or control exists and whether the evidence is sufficient—not simply whether a supplier completed the questionnaire.

5. Go deeper with WCA Human Rights Focus

Where the risk profile calls for on-site assurance, Intertek’s WCA Human Rights Focus audit provides a targeted examination of labour practices, wages and working hours, and social management systems. It is designed to move beyond document review by triangulating management systems, records, worker interviews and workplace evidence. The approach can be adapted to the operating context, including complex or non-factory environments, while maintaining a clear focus on the rights and experience of workers.

This is a critical distinction. An audit is not the whole due diligence programme, but it is an important escalation tool. Connected to Inlight, audit results do not sit in a separate report or inbox. They become part of the supplier risk record and can trigger corrective action, training, re-assessment and management escalation.

6. Prevent, mitigate and remediate

Finding an issue is not the outcome. Inlight links findings to corrective action plans, owners, timeframes, evidence and closure. It allows organisations to see both individual site issues and recurring systemic weaknesses across suppliers or regions. Action can include stopping or changing harmful practices, strengthening controls, using commercial leverage, engaging affected stakeholders, supporting supplier improvement, addressing labour-provider practices and cooperating in remedy. Where disengagement is ultimately necessary, it should be considered responsibly rather than used as an automatic response that may deepen harm to workers.

7. Build capacity around the issues that matter

Training can be linked to supplier gaps, audit findings and recurring programme themes. Targeted eLearning, code-of-conduct training, topic-specific modules and facilitated sessions help strengthen both supplier and internal capability. This turns due diligence from an inspection model into an improvement model and helps prevent the same issues from reappearing.

8. Track effectiveness and retain the evidence

Inlight brings supplier profiles, inherent risk, SAQs, evidence, residual risk, verification, training, audit results, corrective actions and analytics into one environment. Dashboards can show risk movement, open and overdue actions, repeat findings, closure evidence and programme trends. This gives management and boards a more meaningful view than the number of questionnaires issued or audits completed. It shows whether the programme is changing conditions and reducing risk over time.

Local ownership, global reach

Technology alone cannot coordinate thousands of suppliers across languages, time zones and legal contexts. Australian organisations need a team that understands their governance, procurement model, reporting cycle and stakeholders—and can still act wherever their suppliers operate.

Inlight programmes in Australia are supported by a centralised local account, coordination and technical team. That team can manage programme design, supplier communications, campaign delivery, verification, escalation, reporting and ongoing support. Clients have a clear local point of ownership rather than having to coordinate separate technology, advisory, verification and audit providers.

Behind that Australian team is Intertek’s worldwide network of more than 1,000 expert auditors, including the world’s largest social-responsibility auditor network. Local-language auditors and specialists can work close to where suppliers operate, bringing country and industry context while the programme remains centrally governed and consistent.

The real advantage is continuity

Many organisations already have policies, supplier codes, risk assessments, questionnaires, training and audits. The answer is not to discard that work. It is to connect it into a continuous operating system that can show the relationship between risk, decision, action and outcome.

That continuity is what makes the combination of Inlight and WCA Human Rights Focus different. Inlight does not stop at identifying risk, and WCA does not have to remain an isolated audit event. Together they create an evidence trail from supply chain visibility and prioritisation through verification, worker-focused assessment, corrective action, capacity building, remediation and effectiveness review.

The time to build reasonable steps is before they are tested

Australia’s proposed reforms still need to move through consultation and legislation. Businesses should not overstate what the final law will require. They should also not wait for a commencement date before building the supplier visibility, governance and evidence that genuine due diligence requires.

Supplier data takes time to cleanse. Supply chains take time to map. Suppliers need time to engage and build capability. Higher-risk responses need to be verified. Audits need to be delivered. Corrective actions and remediation need time to produce and demonstrate change.

Since 2018, Inlight has been ready for businesses to move from reasonable intentions to reasonable steps. The opportunity now is to build on the work already done, connect the evidence and show not only where risk exists, but what the organisation did about it—and whether people’s lives and working conditions improved. Start with a due diligence readiness review.