Does Your Charity Have to Publish a Modern Slavery Statement or Gender Pay Gap Report?
Key takeaways
- The two duties have unrelated tests: a modern slavery statement turns on turnover from business activities of £36m or more, and gender pay gap reporting on having 250 or more employees in Great Britain.
- Home Office statutory guidance says donations, legacies and grants where the donor receives nothing in return generally do not count towards a charity's £36m, but the turnover of subsidiary undertakings does.
- Section 54 applies only to a body corporate or a partnership, so a charitable company or a CIO can be caught and an unincorporated trust or association cannot.
- A charity in scope must publish its modern slavery statement on its website and link to it from a prominent place on the homepage, which is a template check, not only a content one.
- Gender pay gap figures and the signed statement must stay on the employer's own website for at least three years, so a redesign that drops old reports breaks the rule.
- Action plans are published on the government's gender pay gap service, not your own site, and GOV.UK says they become mandatory from spring 2027 only subject to legislation.
Summary
Some charities do, and the two tests are unrelated. A modern slavery statement is required of an incorporated charity whose turnover from business activities, counted with its subsidiaries, reaches £36m, and it must sit on the website with a link from the homepage. Gender pay gap reporting is required of any employer in Great Britain with 250 or more employees, and the figures stay on the employer's own website for at least three years. Action plans are voluntary now, and GOV.UK says they become mandatory from spring 2027, subject to legislation.
The Short Answer
Only if you meet the test for each, and the two tests have nothing to do with each other.
A modern slavery statement is required of an incorporated charity (a charitable company or a CIO) whose turnover from business activities, counted with its subsidiaries, reaches £36m. Donations and most grants do not count. If you are in scope, the statement goes on your website with a link from the homepage.
A gender pay gap report is required of any employer in Great Britain with 250 or more employees, whatever its income. The figures and a signed statement stay on your own website for at least three years. Action plans are voluntary for now; GOV.UK says they become mandatory from spring 2027, subject to legislation.
The statement is rarely the problem; your finance or HR team probably writes it already. The website is: a homepage link a redesign quietly drops, or a pay gap archive a platform move cuts to one year.
Modern Slavery: Who Is Caught
Section 54 applies to a "commercial organisation" that supplies goods or services and has a total turnover of at least £36m (SI 2015/1833, regulation 2). Section 54(12) defines a commercial organisation as a body corporate or a partnership carrying on a business, or part of one, in the UK. Three consequences follow for charities.
The legal form decides whether you can be caught at all. A charitable company is a body corporate, and so is a CIO (Charities Act 2011, section 205). An unincorporated trust or association is neither, so it falls outside the definition however large it is. The Home Office's statutory guidance (updated 1 December 2025) says an incorporated body is in scope if it engages in commercial activities and meets the threshold, whether or not its aims are "primarily charitable".
Only some income counts. The same guidance has a paragraph on charities. You include income from business activities, "such as the provision of goods and services for a fee". Donations, legacies and grants where the donor receives no service or benefit are generally not treated as business income. It adds a caution: grant income can occasionally count, and a charity should consider whether the funder receives a benefit or attaches conditions to how the grant is used. A charity with large contract income, fee-paying services or significant trading sales should do this sum carefully rather than read its headline income against £36m.
Subsidiaries are added in. Total turnover means the organisation's own turnover plus the turnover of any of its subsidiary undertakings, where turnover is the amount derived from goods and services in their ordinary activities, net of trade discounts, VAT and other taxes (SI 2015/1833, regulation 3). A trading subsidiary's sales are the obvious candidate. How the rule applies to your group structure is a question for your adviser, not your web team.
If you fall below the threshold in a later year, the guidance "strongly recommend[s]" continuing to publish, so that each statement can build on the last.
Where the Statement Goes
Section 54(7) is short. If the organisation has a website, it must publish the statement on it and "include a link to the slavery and human trafficking statement in a prominent place on that website's homepage". Without a website, it must supply a copy within 30 days of a written request (section 54(8)).
The Home Office guidance fills in the rest:
- Prominent "may mean a modern slavery link that is directly visible on the home page or part of an obvious drop-down menu on that page", labelled so the contents are apparent.
- Timing. Publish as soon as possible after the financial year end, and at most within six months of it.
- History. Keep previous years' statements online, so readers can compare them.
- More than one website. Put the statement on the site most closely related to the UK business, and where several are relevant, put a copy or a link on each.
- The registry. Uploading to the government's modern slavery statement registry is encouraged, not required.
The statement itself must be approved by the board (or equivalent management body) and signed by a director or equivalent, under section 54(6). If you do not publish, the Secretary of State can ask the High Court for an injunction to make you (in Scotland, an order for specific performance), under section 54(11).
The website part fails in a predictable place. The homepage is often a bespoke template, and the link that sits in the global footer on every other page may not render there, or may be pushed below a campaign module no one scrolls past. Check the homepage itself, on a phone as well as a desktop.
The Charities Aid Foundation is one public example. On 30 September 2026 its homepage carried a link labelled "Modern slavery statement" in a footer that renders on the homepage itself, leading to a statement page that lists every year from the financial year ended 30 April 2017 to the one ended 30 April 2026. I have not assessed whether CAF is in scope; the page shows the pattern the guidance describes.
Gender Pay Gap: Who Is Caught
The test is headcount, not income. A "relevant employer" has 250 or more employees on the snapshot date (regulation 1), and GOV.UK's guidance on who needs to report applies to England, Scotland and Wales. It counts individuals rather than full-time equivalents, and each separate legal entity with 250 or more employees reports on its own, so a charity and its trading subsidiary are counted separately.
Legal form does not take you out of this one. The regulations set out who signs the statement for an unincorporated body as well as for a company (regulation 14). A large charity with no trading income can be outside modern slavery reporting and inside gender pay gap reporting.
GOV.UK's page on when to report puts charities with private and voluntary employers: a snapshot date of 5 April, and a deadline of 4 April the following year.
Where the Figures Go
Regulation 15 is the website duty. The figures required by regulation 2 and the written statement required by regulation 14 must be published on the employer's website "in a manner that is accessible to all its employees and to the public" and "for a period of at least three years beginning with the date of publication". The figures, and the name and job title of the person who signed the statement, also go on the government's service.
The figures are six: the mean and median hourly pay gaps, the mean and median bonus gaps, the proportion of men and women receiving a bonus and the split by pay quartile (regulation 2). The statement confirms they are accurate and is signed by a director or equivalent (regulation 14). A supporting narrative is optional. GOV.UK's overview says the Equality and Human Rights Commission may take enforcement action for late or inaccurate reporting, and that a late report earns a "late badge" on the government service that the public can see.
The three-year rule is the one a website project breaks. A redesign or platform move that carries over only the current year's report removes the two before it, and nobody notices until someone looks for them. Treat old reports as content that must survive the move; the migration planning guide covers the content inventory that catches them.
CAF again shows the shape. Its gender pay reporting page, linked from the same homepage footer, listed reports from 2019 to 2025 when I loaded it on 30 September 2026.
Action Plans and Spring 2027
Section 33 of the Employment Rights Act 2025, in force from 6 April 2026, inserts section 78A into the Equality Act 2010. It says regulations "may require" employers with 250 or more employees to develop and publish an "equality action plan" on gender equality, including the pay gap and menopause support. It creates the power. The duty depends on the regulations.
GOV.UK's action plan guidance (updated 13 May 2026) states the current position: plans are voluntary, and "Subject to legislation, these will become mandatory from spring 2027." Keep that qualifier when you brief your board. For the 2026 to 2027 reporting year, a voluntary-sector employer can publish its first plan by 4 April 2027, naming a "responsible person", usually a director or senior officer.
For the website, one detail matters most: plans are created, submitted and published on the government's gender pay gap service, not on your own site. Nothing today requires a copy on your website. If you publish a plan, a link to it from your own gender pay gap page puts it where an employee or journalist will look first. When the regulations are made, check the date on this post against them.
Who Owns the Pages
Both documents come back every year, both are signed at board level, and both need their history kept. That makes them governance content with an owner and a date, not a one-off upload. Write them into your website governance policy: a named role, the modern slavery statement live within six months of the year end (the Home Office's recommended maximum), the gender pay gap report live by the 4 April deadline, previous years kept and the homepage link checked after every template change.
A PDF satisfies the letter of both rules, though a short HTML page for each year, with the signed PDF attached, is easier to find and to read on a phone. Neither duty asks much of the website. Both are easy to lose in a redesign, and both are checked by people who know exactly where to look.
Further Reading
- NGO Website Section Checklist: row 84, Modern slavery statement
- NGO Website Section Checklist: row 85, Gender pay gap
- Website Governance Policy for Nonprofits: What to Include and Why
- Website Migration Planning for Nonprofits: A Governance Approach
- Publishing Your Nonprofit Annual Report Online
What This Post Does Not Cover
These are not Charities Act duties, which is why the Charity Commission website requirements page does not carry them. The NGO website section checklist tags both as Conditional: required only once you meet the test.
This post is about the publication duty: who is caught, what the site must show and who keeps it current. It is not legal or HR advice. Whether your charity is in scope is a decision for your auditor, legal adviser or HR lead, not your web team.
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Frequently asked questions
- Do donations count towards the £36m modern slavery threshold for a charity?
Generally not. The Home Office's statutory guidance says a charity should count income from business activities, such as goods and services provided for a fee, and that donations, legacies and grants where the donor receives no service or benefit generally do not count. It adds that grant income can occasionally count, depending on whether the funder receives a benefit or attaches conditions to how the money is used. The turnover of subsidiary undertakings, such as a trading subsidiary, is included under regulation 3. Whether your income reaches £36m on that basis is a question for your auditor or legal adviser.
- Is a footer link enough for the modern slavery statement?
Section 54(7) requires a link in a prominent place on the homepage. The Home Office guidance says that may mean a link directly visible on the homepage or part of an obvious drop-down menu, clearly labelled. It does not mention footers either way. A clearly labelled link that actually renders on the homepage template is the minimum; check it rather than assuming the global footer appears there.
- Where do gender pay gap action plans get published?
On the government's gender pay gap service, where they appear alongside your data, according to GOV.UK's action plan guidance. There is no duty today to publish one on your own website. The 2017 regulations' own-website duty covers the figures and the signed statement.
- Our charity has fewer than 250 staff but a trading subsidiary. Do we report?
GOV.UK's guidance on who needs to report says the duty applies to each separate legal entity with 250 or more employees on the snapshot date, so you count the charity and the subsidiary separately. Headcount is individuals, not full-time equivalents. If neither entity reaches 250, neither has to report, though either can choose to. The NGO website section checklist carries the row.
- Who should own these pages?
A named role, with the dates written into the website governance policy: the modern slavery statement within six months of the financial year end, as the Home Office guidance recommends, and the gender pay gap report by the 4 April deadline that applies to charities. The website governance policy guide covers how to assign a page owner and a review date.