At the end of October the Home Office published statutory guidance on the new requirement under section 54 of the Modern Slavery Act 2015 for larger commercial organisations to produce an annual 'transparency in supply chains' statement. On the same day regulations came into force specifying enforcement dates for the new rules.

Businesses with a year end of 31 March 2015 will need to produce a statement for their current financial year ending 31 March 2016 (catching many businesses whose financial year follows the tax year) but organisations with a year-end on 30 March 2016 will not need to produce the statement until the financial year-end in March 2017. The guidance says the statement must be published 'as soon as practicable' after the financial year-end and indicates that six months would be acceptable. This means the first statements, technically due from 31 March 2016, may not need to be published until around September next year.

The new rules apply to organisations that are a 'body corporate' or a partnership, carrying on a business, or part of a business, in the UK which supplies goods and services, and which has an annual turnover of £36m or more - the regulations confirm this includes the turnover of the organisation and its subsidiaries whether or not these are in the UK. So a UK parent company with a turnover of less than £36m could still be caught by its overseas subsidiaries. The guidance also specifies which company within a group of companies must prepare the statement and how associated companies may make use of it.