Strengthening Australia’s response to Modern Slavery in supply chains
31 August 2026
AFGC is seeking member feedback on the Attorney-General’s Department consultation on proposed reforms to strengthen Australia’s response to modern slavery in supply chains.
Please provide feedback to AFGC by Friday 11 September 2026.
Government submissions close Friday 25 September 2026.
The Government announced on 16 July 2026 that it intends to introduce a new criminal offence for failure to prevent modern slavery. The consultation will inform the design of that offence and related enforcement options.
This consultation is separate from the earlier review of the Modern Slavery Act 2018 reporting framework. It focuses on the proposed criminal offence, related enforcement options, and possible remedies for victims and survivors.
What the Government is considering
- the proposed failure to prevent modern slavery offence, including its scope, application and defence
- whether a Deferred Prosecution Agreement scheme should apply to relevant modern slavery offences
- possible avenues for victims and survivors to pursue civil remedies
The Government says the reforms should be practical, effective and proportionate, while strengthening corporate accountability and action to prevent modern slavery risks.
Why this matters for members
Food and grocery supply chains can involve multiple suppliers, labour providers, commodities and jurisdictions. The practical impact of any new offence will depend on how far responsibility extends through supply chains and what businesses are reasonably expected to do where they have limited visibility or leverage.
For members, the key issue is how the proposed offence, its application and defence would operate in practice across complex supply chains, including where businesses have limited visibility or leverage.
What we need from members
We are particularly interested in practical examples and views on:
- how far through a supply chain the proposed offence should apply
- what connection should be required between a business and the modern slavery conduct
- what should count as reasonable steps to prevent modern slavery
- current supplier due diligence, risk assessment, audit and remediation processes
- situations where your business has limited visibility, influence or reliable information
- challenges in obtaining information from international or multi-tier supply chains
- where clearer government guidance would be needed
- likely additional legal, assurance, systems or administrative costs
- the proposed Deferred Prosecution Agreement model and potential civil remedies
Where possible, please include examples of the practical impact on your business, including staff time, external costs, supplier engagement requirements or other compliance impacts.
Timing and government engagement
Member feedback to AFGC: Friday 11 September 2026
Government submission deadline: Friday 25 September 2026
Next steps
AFGC will use member feedback to inform its submission. Members do not need to respond to every consultation question. Examples that show how the proposed offence could operate across complex supply chains will be particularly useful.
AFGC will de-identify all sensitive information.
Contact: Sarah Collier, Director Membership & Sustainability
sarah.collier@afgc.org.au
