Small businesses could get relief from the repeated modern slavery questionnaires imposed by their larger customers under proposals from Australia's Anti-Slavery Commissioner. But with tougher legal obligations planned for large companies, pressure on suppliers to demonstrate they have addressed modern slavery risks is unlikely to ease.
Commissioner Chris Evans published Getting the Balance Right: Modern Slavery Due Diligence and SMEs on October 19, proposing risk-based information requests, shared due diligence infrastructure and greater SME involvement in industry collaboration. The aim is to reduce duplicated work without weakening efforts to identify and address modern slavery.
For insurance brokers advising SME clients, the issue goes beyond paperwork. The contractual assurances businesses give customers may carry liability implications, particularly if proposed reforms make large companies more demanding about the evidence they expect from their supply chains.
"This is not a call for less due diligence, it is a call for smarter due diligence," Evans said. "The challenge is ensuring that due diligence efforts are focused on genuine risks, rather than repetitive administrative processes."
In July, the government announced plans for a new criminal offence for companies with revenue over $100 million that fail to prevent modern slavery in their operations and supply chains, with a defence for those that can show they took reasonable steps. The Attorney-General's Department has consulted on the offence's design, including a possible Deferred Prosecution Agreement scheme. A defence built on documented steps gives large companies a strong reason to keep asking their suppliers for evidence, and many of those suppliers are SMEs.
Evans said he has written to the responsible ministers about the paper, which builds on his broader reform framework, Impact through action, released on October 15.
The paperwork reaches into broking too. Large reporting entities in the sector already assess modern slavery risk across their networks. Steadfast's 2025 modern slavery statement, for example, addresses risk across its network brokers and underwriting agencies.
For brokers with SME clients, the questionnaires are the visible cost, but the contractual obligations clients are asked to sign alongside them deserve a closer look. Where those obligations include warranties or indemnities to a large customer, it is worth checking whether the client's liability cover would actually respond, before the offence makes large customers more insistent on them.
