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The Modern Slavery Act 2018 (NSW) (‘the Act’) and related legislation created new due diligence and reporting obligations for certain public entities in New South Wales.
To find out if your entity has due diligence or reporting obligations, read the section ‘Covered Entities’ below.
The NSW Anti-slavery Commissioner (‘the Commissioner’) developed the Shared Implementation Framework (‘the Framework’) in consultation with covered entities, to assist covered entities to effectively discharge their new obligations under the Act.
The Framework is designed to apply not only to entities that participate in the NSW Procurement Policy Framework – governed by the NSW Procurement Board – but also to other entities that do not participate in that framework but have due diligence or reporting obligations under NSW law. This includes local councils, certain universities in New South Wales, Local Aboriginal Land Councils, and others.
The Framework may be updated by the Commissioner from time to time, after further consultation with covered entities.
Currently the Framework consists of five elements:
More than 400 public entities in New South Wales have due diligence or reporting obligations relating to modern slavery, under NSW law.
To find out more, including if your entity is one of the covered entities, download and read the document GRS Resource: Covered entities (PDF, 200.3 KB).
The centrepiece of the Framework is the NSW Anti-slavery Commissioner’s Guidance on Reasonable Steps to Manage Modern Slavery Risks in Operations and Supply-Chains (‘Guidance’ or ‘GRS’).
The Guidance aims to assist covered entities in applying clear policies, consistent procedures, and effective risk management strategies for modern slavery risks in their operations and supply-chains. It provides guidance on how to prevent, identify, mitigate, address, and remediate modern slavery risks and harms in operations and in supply-chains.
The Guidance sets out the main issues and concepts that covered entities need to understand to meet reporting and due diligence expectations under NSW law. It should be read together with the other elements of the Framework set out here.
Download the Guidance on Reasonable Steps (PDF, 2.6 MB).
Many covered entities have annual reporting obligations under NSW law. The legislative provisions in relation to the publication of annual modern slavery reporting information differ depending on the type of covered entity (refer to GRS Resource: Covered entities (PDF, 200.3 KB)). Entities should carefully review their relevant legislative provisions to confirm their obligations and seek legal advice if required.
Covered Entities with annual reporting obligations should report in two places:
1. By including relevant information in their entity’s formal annual report.
The timing for this report is determined by other legislation or your entity’s policies. The Office of the NSW Anti-slavery Commissioner provides an Annual Reporting Template at Appendix K in the Guidance (DOCX, 32.5 KB) to assist this process.
2. Using the online GRS Annual Reporting Form.
The GRS Annual Reporting Form is an online form which allows covered entities to share data directly with the Office of the NSW Anti-slavery Commissioner. A version of the GRS Annual Reporting Form can also be found at Appendix K of the Guidance. You should complete and submit this form upon publishing your Annual Report.
Download the GRS Resource: Instructions for Annual Reporting (PDF, 296.6 KB)
More information about your reporting obligations is provided in the Guidance (GRS).
Reporting relates to all activity since 1 July 2022, when the relevant legal obligations under NSW law took effect. However, the GRS takes effect from 1 January 2024. Accordingly:
The GRS Inherent Risk Identification Tool ('the IRIT') is a simple-to-use risk mapping tool intended to allow covered entities to identify the modern slavery risk associated with different product categories from which they procure. Further due diligence on specific suppliers is also required, but the IRIT provides a common baseline for understanding modern slavery risk across NSW public buyers at the category level.
The IRIT was developed by the Office of the NSW Anti-slavery Commissioner with support from the Institute of Transport and Logistics Studies at the University of Sydney Business School.
An updated version 2.0 of the IRIT was published in May 2025. For more information, see GRS Announcement: Release of Inherent Risk Identification Tool V2.0.
All covered entities are expected to use version 2.0 of the IRIT for their due diligence activities from the start of their FY2025-2026 or calendar year 2026 reporting year, i.e. from:
You should continue to use version 1.1.2 of the IRIT for your FY2024–2025 or calendar year 2025 reporting.
The IRIT will be periodically reviewed and updated, drawing on the latest available reliable evidence.
Download the Inherent Risk Identification Tool (version 2.0) (XLSX, 4.8 MB).
Download the Inherent Risk Identification Tool (version 1.1.2 – SUPERSEDED)
Download the GRS Resource: Modern Slavery Risks in Construction: An Overview (PDF, 307.4 KB).
Download the GRS Resource: Using the Inherent Risk Identification Tool (IRIT).
The GRS Model Tender Clauses on modern slavery have been prepared by the Office of the NSW Anti-slavery Commissioner. The GRS Model Tender Clauses are intended as a resource for NSW public entities and should be read together with the Guidance.
The GRS Model Tender Clauses can also be found at Appendix I of the Guidance.
Download the GRS Model Tender Clauses:
The GRS Model Contract Clauses on modern slavery have been prepared by the Office of the NSW Anti-slavery Commissioner. They were prepared with generous support from the Responsible Contracting Project (RCP) and their pro bono counsel, Allens.
The GRS Model Contract Clauses are intended as a resource for NSW public entities and should be read in conjunction with the Guidance.
The GRS Model Contract Clauses can also be found at Appendix J of the Guidance.
Download the GRS Model Contract Clauses:
Version 1.0 of the GRS (December 2023) outlined an expectation that covered entities will file an online report about each contract the entity is a party to that commences on or after 1 July 2024, has a value of AU $150,000.00 (incl. GST) or more, and requires Heightened Modern Slavery Due Diligence on the GRS Due Diligence Level scale (see Appendix L of the GRS). As explained below, the timeline for this requirement has been postponed.
This HMSDD Reporting is separate from the requirement to include information about reasonable steps in your formal annual report.
The Commissioner notes feedback from covered entities about growing compliance burdens on NSW government procurement personnel arising from multiple statutory reporting regimes. With this in mind, and to ensure adequate time for covered entities to prepare for effective implementation of HMSDD reporting, the Commissioner has decided to postpone the introduction of detailed HMSDD reporting.
More details about reporting arrangements will be announced in the coming months, with significant notice to allow covered entities to integrate compliance into relevant policies and procedures.
Note: This revised timeline does not affect covered entities’ statutory annual reporting obligations. Ensure you report annually on your modern slavery risk management efforts within the deadlines applicable to your entity. For more detail on annual reporting, see Appendix K to the GRS (DOCX, 32.5 KB) and GRS Resource: Instructions for Annual Reporting (PDF, 296.6 KB).
The GRS Public Register is required under section 26 of the Act.
The GRS Public Register:
These GRS Resources are intended to support covered entities to implement the Guidance. New resources will be added as they become available. These will include:
The Commissioner is collaborating with Capability Development, NSW Procurement to develop a series of short eLearning modules, available on Comperio, the NSW Government training platform. These eLearning Modules will assist covered entities to understand and implement the GRS.
These eLearning modules are available at the links below.
Note: The Introduction to Modern Slavery and Your Obligations and Foundational Concepts for Managing Modern Slavery Risk courses are pre-requisites to subsequent courses, and must be completed first.
For any questions access to the Comperio Platform, please contact nswp_capability@treasury.nsw.gov.au.
News and updates related to the Shared Implementation Framework:
For advice and support relating to the Shared Implementation Framework, contact the Office of the NSW Anti-slavery Commissioner at GRS@dcj.nsw.gov.au
If you have any trouble accessing the documents on this page or to request an accessible version, please contact GRS@dcj.nsw.gov.au
To stay up to date with the latest news announcements relating to this Framework, sign up for the OASC Due Diligence newsletter here.
We expect this module to be published on Comperio by the end of May. After the module is published, we will request that an external hyperlink to the Comperio page is added.
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