[Home](/)/[Resources](/resources)/Australia Modern Slavery Act AustraliaSupply Chain # Australia Modern Slavery Act: Supply Chain Reporting for Hardware Companies Hardware supply chains touch some of the highest-risk areas for modern slavery — from conflict mineral extraction to PCB assembly. The Australian Modern Slavery Act 2018 requires large entities to report publicly on how they identify and address those risks — and the public register makes the quality of that reporting visible to investors, customers, and regulators. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Faustralia-modern-slavery-act) At a glance Law Modern Slavery Act 2018 Administrator Department of Home Affairs / Australian Border Force Threshold AUD 100M consolidated annual revenue Statement Annual, due 6 months after year end ## What the Modern Slavery Act requires ### Who must report Reporting entities include Australian entities and foreign entities carrying on business in Australia with consolidated annual revenue of at least AUD 100 million. Subsidiary entities below the threshold can be covered under a parent entity's consolidated statement. The threshold applies to global consolidated revenue, not just Australian revenue. ### Seven mandatory reporting criteria The statement must address: the entity's structure, operations, and supply chains; the risks of modern slavery in those operations and supply chains; the actions taken to assess and address those risks; how the entity assesses the effectiveness of those actions; consultation with owned or controlled entities; any other relevant information; and the identity of the approving officer (board or equivalent). ### Modern Slavery Statements Register Statements are submitted to the Australian Border Force (ABF) and published on the government's public register. Any person can search the register — making statement quality a reputational issue as well as a compliance one. The ABF publishes annual assessments of statement quality across industries. ### Electronics supply chain risk areas The Global Slavery Index and Responsible Business Alliance (RBA) flag several high-risk areas relevant to electronics hardware: mineral extraction (cobalt, tantalum, tin, tungsten, gold — the 3TG minerals and cobalt), PCB assembly in certain regions, semiconductor fabrication, cable and connector manufacturing, and solar panel manufacturing. Due diligence should be proportionate to the risk level of each supply chain tier. ## How to prepare and submit your modern slavery statement 01 Confirm whether your entity meets the AUD 100 million consolidated revenue threshold — for foreign entities, this is based on global consolidated revenue from all activities, not just Australian revenue; if below the threshold, voluntary reporting is still permitted and increasingly expected by institutional investors. 02 Map supply chains to identify goods and services with modern slavery risk — for hardware companies this includes semiconductor fabrication, PCB assembly, cable and connector manufacturing, raw material sourcing (cobalt, tantalum, tin, tungsten, gold), and logistics providers in high-risk regions. 03 Conduct due diligence proportionate to risk — higher-risk suppliers warrant on-site audits or third-party social compliance audits (RBA VAP, Sedex SMETA, SA8000); lower-risk suppliers can be assessed through self-assessment questionnaires and contractual representations. 04 Draft the modern slavery statement covering all seven mandatory criteria — be specific about what risks were found and what actions were taken; generic statements that describe process without disclosing actual risks score poorly on the ABF assessment criteria and attract public scrutiny. 05 Have the statement approved by the board of directors (or equivalent governing body) and signed by a responsible member — then submit via the Australian Modern Slavery Statements Register by the due date, which is six months after the financial year end. ## Frequently asked questions ### Which companies must report under Australia's Modern Slavery Act? Australian entities and foreign entities carrying on business in Australia with consolidated annual revenue of at least AUD 100 million must submit an annual modern slavery statement. This threshold applies to global consolidated revenue, not just Australian revenue — so a large foreign hardware company with even modest Australian operations may be caught. Entities below the threshold are not required to report but may do so voluntarily, and many do to meet investor expectations. ### What is the difference between the Australian and UK Modern Slavery Acts? Both acts require supply chain transparency statements, but there are key differences. The Australian Act applies at AUD 100 million (approximately GBP 50 million) consolidated revenue; the UK Act applies at GBP 36 million. The Australian Act specifies seven mandatory reporting criteria; the UK Act is less prescriptive. The Australian Act requires statements to be submitted to a central government register; the UK Act requires publication on the company's website. Australia is reviewing whether to introduce financial penalties for non-compliance; the UK Act currently has no penalties for late or poor-quality statements. ### What supply chain risks are most relevant for electronics hardware companies? The highest-risk areas in electronics supply chains include: extraction of cobalt (Democratic Republic of Congo), tantalum, tin, tungsten, and gold (conflict minerals); PCB assembly in certain South and Southeast Asian manufacturing regions; solar panel manufacturing (flagged for forced labour risks in certain geographies); and garment and packaging manufacturing. The Responsible Business Alliance (RBA) Code of Conduct and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected Areas provide frameworks specifically relevant to electronics hardware. ### Are there penalties for not submitting a modern slavery statement? The Modern Slavery Act 2018 does not currently impose direct financial penalties for failing to submit a statement. The Australian Border Force can require a reporting entity to explain its non-compliance and publish that explanation. The government has flagged that financial penalties may be introduced in future amendments. The greater practical consequence of non-compliance is reputational: the public register makes non-reporters visible to investors, customers, and NGOs, and institutional procurement increasingly requires demonstrated compliance. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇦🇺 Australia roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇦🇺 Australia compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/44-australia-rcm-marking-electronics-cabling)[Prefer to read? Get the book — $24.99](/books/44-australia-rcm-marking-electronics-cabling) Related guides * [UK Modern Slavery Act Supply ChainUK Modern Slavery Act 2015 Section 54 transparency statements: six reporting areas, the government registry, electronics supply chain risk areas, and CSDDD comparison.](/guides/uk-modern-slavery-act-supply-chain) * [Canada Modern Slavery Supply ChainCanada Fighting Against Forced Labour Act (S-211): who must report, the eight mandatory report elements, May 31 annual filing deadline, board attestation, and hardware supply chain mapping.](/guides/canada-modern-slavery-supply-chain) * [EU Forced Labour RegulationRegulation (EU) 2024/3015 bans products made with forced labour from the EU market: risk-based investigation, rebuttable presumption, remediation obligations, and CSDDD alignment.](/guides/eu-forced-labour-regulation) * [Australia Packaging CovenantAustralian Packaging Covenant (APCO): the 2025 National Packaging Targets, annual PREP recyclability report, membership obligations for electronics brand owners, and polystyrene foam compliance.](/guides/australia-packaging-covenant) * [Australia Critical Minerals Supply ChainAustralia's Critical Minerals Strategy 2023-2030 for electronics manufacturers: the 31-mineral Critical Minerals List, Export Finance Australia support, FTA rules of origin, and Modern Slavery Act obligations on lithium, cobalt, nickel, and rare earth sourcing.](/guides/australia-critical-minerals-supply-chain)