Australia's Modern Slavery Act and Pakistan: What Australian Buyers Are Now Required to Do

Walk Free Foundation, an Australian-based organization focused on modern slavery, has produced multiple analyses of Australian MSA statement quality. Academic researchers at the University of Technology Sydney and other institutions have published peer-reviewed analyses of Australian MSA statements. The Business and Human Rights Resource Centre tracks them. These analyses name companies. They identify gaps. They compare year-on-year improvement, or its absence. Being named in a poor-quality statement analysis has reputational consequences that a purely internal filing requirement doesn't carry.

This public accountability dimension changes the compliance calculus significantly.

Who the Australian Act captures beyond Australian companies

The Act's scope is broader than many foreign companies operating in Australia recognize. A foreign company carrying on business in Australia with consolidated global revenue above AUD 100 million is within scope, regardless of where it is incorporated or headquartered.

"Carrying on business in Australia" for a foreign company typically means having a branch, subsidiary, or commercial presence in Australia through which commercial activities occur. A UK fashion brand with an Australian retail operation or e-commerce presence targeting Australian consumers and generating Australian revenue is likely within scope. A US company with Australian sales offices meets the threshold.

For Pakistani suppliers who sell to Australian buyers, the Act imposes obligations on those buyers, not directly on the Pakistani suppliers. But the obligations those buyers carry flow back into what they need to know about and document about their Pakistan supply chains. The seven mandatory reporting areas and what Pakistan-specific compliance looks like

Australia's seven mandatory reporting areas are similar but not identical to the UK's six. They cover:

The entity's structure, operations, and supply chains. For Pakistan-sourcing Australian buyers, this means being specific about what is sourced from Pakistan, which manufacturing sectors it touches, and how the supply chain is structured from fiber to finished product.

The modern slavery risks in those operations and supply chains. An honest risk assessment for Pakistan identifies the documented risk concentrations: cotton farming labor practices in Sindh and Punjab, home-based embellishment work, informal sub-contracting in peak production periods. These are not risks that apply to all of Pakistani manufacturing. They are concentrated in specific supply chain tiers and sectors. The specificity is what makes a risk assessment credible.

The actions taken to assess and address those risks. This is where most statements have the largest gap between rhetoric and evidence. "We work with our suppliers to improve conditions" is not an action. "We required all Tier 1 suppliers to complete sub-contractor disclosure forms, extended SMETA audit requirements to three wet processing sub-contractors, and incorporated Better Cotton sourcing requirements for cotton-origin product lines" describes actual actions with traceable consequences.

How the entity consults with entities it owns or controls. For large buyers with subsidiary operations sourcing from Pakistan, this covers the consultation process within the corporate group.

Any other relevant information. This catch-all is where leading companies include positive actions, industry collaboration memberships (Better Work, Better Cotton Initiative), and systemic engagement efforts.

Effectiveness assessment. What performance indicators does the organization use? What do the data show? A statement that includes actual KPI data, including unflattering data where improvement is needed, is more credible than one that claims general progress.

Training. Who receives it, what it covers, how its effectiveness is assessed.

The Home Affairs quality review process

Starting from 2020, the Australian Department of Home Affairs has published annual analyses of submitted statements, reviewing them against basic compliance criteria. The criteria check whether the statement has been signed by a principal governing body member or equivalent, whether it covers the mandatory reporting areas, and whether it's submitted within the required timeframe. The compliance rates in early years were lower than many expected. A significant proportion of statements failed basic criteria on first review. Home Affairs has escalated this process, publishing names of non-compliant entities and, in some cases, making direct contact to require resubmission.

Beyond basic compliance, the quality gap between statements is wide and publicly visible. Leading statements in Australia's registry describe genuine systems, real data, and honest acknowledgment of where gaps remain. Trailing statements describe good intentions and reference codes of conduct with no evidence of implementation.

Pakistan-specific considerations for Australian buyers

Australian buyers sourcing from Pakistan typically concentrate in several categories: knitwear and casual apparel, cotton home textiles, leather goods, and sporting equipment from Sialkot.

For knitwear and casual apparel: the supply chain risk areas for Australian buyers are the same as for UK and EU buyers. Cotton farming practices in Sindh and Punjab, sub-contracted wet processing without adequate monitoring, and home-based embellishment work for more complex garment types. Australian buyers face the same structural visibility gaps that UK and EU buyers face, requiring the same systematic approach of Tier 1 social audits plus sub- contractor disclosure plus Tier 2 extension for high-risk facilities.

For cotton home textiles: the cotton farming tier risk is the primary area requiring attention. Australia's cotton industry is itself significant and Australian buyers in this category are sometimes more attuned to agricultural labor standards than fashion buyers, which creates a foundation for more sophisticated farming-tier due diligence.

For leather goods from Sialkot: the relevant modern slavery considerations include chemical exposure conditions in tanneries, working hours in production, and sub-contracting chain visibility in the highly specialized Sialkot cluster. The cluster's export orientation and long- standing international buyer relationships at the major manufacturer tier create generally better Tier 1 compliance conditions. The sub-contracting and home-based stitching tiers require more attention.

The practical action list for Australian buyers

Audit your statement against the seven mandatory areas now, not at filing time. Gaps identified before the reporting period ends can be addressed. Gaps identified after filing can't.

Build sub-contractor disclosure into every Pakistan supplier agreement. Name it explicitly in the contract. Make non-disclosure a breach. Update it semi-annually.

Add Pakistan-specific risk context to your buyer training programme. "Modern slavery risk in supply chains" as a generic topic is less useful than "home-based embellishment workers in Pakistan's garment supply chain: what the risk looks like and what we do about it."

Engage with industry initiatives that provide some leverage in the tiers you can't directly audit. Better Cotton Initiative membership for cotton-origin products, ZDHC programme engagement for chemical compliance that correlates with labor conditions, and Better Work where it operates.

Document everything as you do it. The Australian MSA statement requires you to describe what you did. If you did good work and didn't document it, your statement can't reflect it.

For supply chain documentation and environmental compliance support for Australia-bound Pakistan supply chains, contact Tti Labs at customerservices@ttilabs.net.