Since its introduction in 2018, Australia’s Modern Slavery Act has gradually reshaped corporate approaches to supply-chain governance. The Act started by focusing primarily on large corporations with obvious physical supply chains — manufacturing, agriculture, logistics. But as e-commerce has boomed, so too has recognition that modern slavery risks don’t stop at traditional production floors or shipping containers. In fact, digital platform marketplaces — hosting thousands of sellers, sometimes millions — have emerged as a new frontier for compliance. That’s precisely what the 2024 amendments to the Act have addressed. They’ve expanded the reporting scope to cover digital marketplaces operating in or serving Australian consumers, bringing a layer of complexity that many platform operators are still grappling with.
The underlying rationale is hard to dispute. Online marketplaces connect buyers to goods sourced globally, often with little visibility into who the actual seller is, or where goods originate beyond whatever declarations are made at the point of listing. Without mechanisms to verify these declarations, the risk is obvious: unethical actors can use digital storefronts to sell products tainted by forced or child labour, sometimes hidden several layers deep in their own sourcing arrangements. This wasn’t a theoretical risk. Multiple investigations over the past few years have uncovered supply chains linked to modern slavery being laundered through online platforms — particularly where goods are drop-shipped from opaque offshore suppliers.
So, what does compliance look like in this evolving environment? For Australian e-commerce platforms, one of the most immediate steps is integrating API-based checks against external datasets — the Slavery Footprint database, for example, has emerged as a widely referenced resource. The idea isn’t that these tools will catch everything (no tool will, realistically), but that they form part of a systematic due diligence process. An API connection allows a platform to automatically screen product categories, material declarations, or even geographic indicators against known high-risk profiles. The technology itself isn’t especially novel — what matters more is how platforms embed it into their onboarding and monitoring processes.
There’s a tendency, perhaps understandable, for compliance teams to overestimate what these integrations can achieve on their own. Yes, API checks can flag potential risks, but they need to be combined with human review and judgment. After all, datasets like Slavery Footprint rely on publicly reported violations, media sources, NGO investigations — in short, they’re only as complete as the information fed into them. A supplier operating unethically but under the radar won’t necessarily trigger a digital red flag. That’s why platforms also need procedures for escalating checks where API results or other indicators suggest heightened risk. Some platforms are building internal risk committees to review seller profiles on a rolling basis — an approach that can help balance automation with accountability.
A critical operational challenge is cross-referencing seller IDs — especially given the ease with which sellers can change names, rebrand, or open new accounts. This is where cross-checking against human-rights violation databases becomes more complex. It’s rarely as simple as matching a name in one database to a name in another. Seller identities might shift slightly, or be shielded behind layers of intermediaries. Platforms therefore need to think carefully about how they structure and link their internal seller records — creating persistent IDs that follow a seller across multiple storefronts, trading names, or legal entities. Some have begun experimenting with digital identity verification tools to strengthen this linkage at the onboarding stage.
There’s also the question of how much data can realistically be processed without overwhelming teams or creating friction that discourages legitimate sellers. Automating basic cross-checks helps, but platforms need to calibrate their systems so they don’t generate so many alerts that meaningful risks get lost in the noise. This balance — between vigilance and practicality — is proving one of the tougher aspects of implementation. It’s not helped by the lack, at this point, of standardised frameworks on what constitutes an adequate digital monitoring program under the Act’s amended scope. Guidance has been issued in broad strokes, but the operational details are largely being worked out through industry experimentation.
In practical terms, platforms may want to focus first on categories with the highest documented modern slavery risks: apparel, footwear, electronics accessories, home goods involving wood or textiles. Prioritising these for enhanced monitoring makes sense both from a risk-based and resource-allocation perspective. Some platforms have gone further — introducing voluntary seller codes of conduct that commit vendors not only to legal compliance but also to proactive transparency about sourcing. The effectiveness of such codes is variable. Much depends on how they’re enforced, and whether sellers perceive them as meaningful conditions of participation rather than boilerplate.
It’s probably worth mentioning that smaller platforms face particular challenges here. Large multinationals can afford dedicated compliance teams, systems integrations, and external audits. For SMEs running niche marketplaces, the burden of digital supply-chain monitoring can feel disproportionately heavy. There’s ongoing discussion — both within industry groups and in government circles — about how best to support these smaller operators, possibly through shared verification tools or pooled due-diligence services. But concrete solutions remain at an early stage.
Looking ahead, one question looms: will consumers engage with these measures in any meaningful way? Transparency frameworks assume that better data will drive better choices, but whether shoppers read or act on slavery risk disclosures attached to a product listing is, frankly, an open question. For now, platforms are focusing — rightly — on compliance with legal obligations. But over time, how these monitoring systems intersect with consumer behaviour may determine their ultimate impact.
The shift to digital supply-chain monitoring under Australia’s Modern Slavery Act marks a significant evolution in how anti-slavery reporting is understood and operationalised. It’s not without friction. But it reflects a reality: as commerce moves online, so too must due diligence.