The Modern Slavery Assessment Tool is easy to underestimate. Many suppliers assume that if they already have a modern slavery statement in place, the rest will be straightforward. In NHS procurement, that assumption often causes problems.
MSAT tests how well an organisation identifies and manages modern slavery risk across its operations and supply chain. For NHS suppliers, weak or outdated evidence quickly becomes a compliance issue, especially where the assessment is a pass/fail requirement.
At Bidding, we often see suppliers treat this as a policy exercise when it is really a question of risk management, evidence and consistency. The suppliers that handle it well do more than produce the right statements. They show that their controls, due diligence and governance stand up to scrutiny.
MSAT is the Government’s Modern Slavery Assessment Tool. Its purpose is not simply to check whether a supplier has published a statement. It assesses how well an organisation identifies, manages and improves its response to modern slavery risk. NHS England describes it as a risk identification and management tool, while NHS Supply Chain says all suppliers must complete and maintain an up-to-date MSAT as a minimum requirement.
That distinction matters because suppliers sometimes approach MSAT as a form-filling exercise. The tool is really about maturity and risk management. It looks at whether the organisation can show a structured response to labour exploitation risks in its own operations and supply chain.
For suppliers bidding into NHS Supply Chain opportunities, the consequences can be more direct. Completion of the Modern Slavery Assessment Tool is a mandatory pass/fail requirement at selection stage for its tenders.
The regulatory picture is tightening. It’s more important than ever for suppliers to understand how NHS procurement regulations and policy and shaping modern slavery expectations.
The Health and Care Act 2022 introduced a basis for new regulations addressing modern slavery risk in NHS supply chains, and updated guidance on tackling modern slavery in NHS procurement was published in October 2025. The NHS has standardised its approach to identifying and addressing modern slavery risk through procurement, including use of the Modern Slavery Risk Assessment Tool at pre-procurement stage and the government’s Modern Slavery Assessment Tool in contract management for gold contracts.
NHS Supply Chain has also set a practical benchmark for suppliers. Suppliers are expected to achieve a minimum score of 41% on MSAT, reflecting a baseline level of maturity in identifying and managing modern slavery risks, and it encourages suppliers to review and update responses at least annually.
That means the risk is not only that a supplier fails to complete the tool. The risk is that it completes it weakly, leaves it outdated or assumes a low-quality response will go unnoticed.
The cause of most MSAT problems is not a total lack of awareness. Instead, weak preparation is often to blame.
A common issue is overreliance on the annual modern slavery statement. That statement may be required under legislation, but it does not automatically prove that the organisation has effective due diligence, training, escalation processes or supplier monitoring in place. Buyers and contract managers will often look for signs that the statement reflects real practice.
Another problem is fragmentation. HR owns one part of the issue, procurement owns another, legal owns the policy wording and nobody is fully responsible for the overall evidence set. That often leads to inconsistent answers across different documents and procurement processes.
There is also the problem of generic language. Suppliers sometimes use broad claims about ethical standards or zero tolerance without being able to show how risks are identified, what happens when concerns arise or how supplier assurance is managed in practice. That can leave an MSAT response looking polished but thin.
At Bidding, we also see trouble where modern slavery evidence is treated completely separately from other procurement requirements. In reality, buyers may read it alongside wider supply chain, social value and contract management evidence. If those areas tell different stories, confidence drops.
A stronger MSAT response rests on a few practical foundations.
First, ownership must be clear. Someone needs clear responsibility for modern slavery risk, and that responsibility needs to connect with the teams handling procurement, supplier onboarding and contract management.
Second, the evidence must be current. Policies, statements, training records and due diligence processes need to reflect what the organisation is doing now, not what it intended to do two years ago.
Most importantly, the organisation must be able to explain its approach in practical terms, not just policy language. A supplier operating in a higher-risk category, geography or labour model will not reassure a buyer by repeating the right phrases. It needs to show how it identifies risk, responds to issues and improves over time.
This is also why the topic overlaps naturally with social value in NHS tenders and common NHS contract terms. Modern slavery is not only an ethical issue. It is now part of how the NHS evaluates, contracts and monitors its suppliers.
The safest approach is to treat MSAT as part of bid readiness rather than as an admin task to complete only when a tender appears. This is especially true for suppliers regularly pursuing healthcare tenders.
A sensible review process includes:
For suppliers targeting NHS Supply Chain, this preparation matters even more because the tool operates as a selection-stage pass/fail requirement.
One of the easiest mistakes suppliers make is to treat each compliance topic as separate. In practice, the NHS is moving towards a more connected view of supplier readiness.
Suppliers can share progress on modern slavery with NHS commercial teams through the Evergreen Sustainable Supplier Assessment in Atamis. Social value requirements also connect directly to the elimination of modern slavery through the Government’s model. In practice, that means a supplier’s MSAT position may be visible to NHS commercial teams as part of a wider sustainability and compliance profile, not just during a single tender.
That means MSAT should not be prepared in isolation. If a supplier’s modern slavery evidence is weak, there is a good chance related areas such as supply chain governance, social value commitments or contract management arrangements will also look weaker under scrutiny.
The suppliers that manage MSAT best are usually not the ones with the longest policy documents. They are the ones that can show a clear, consistent and current approach to managing modern slavery risk.
For NHS suppliers, that means treating MSAT as part of a broader compliance framework rather than as a one-off hurdle. When the evidence is joined up, the tool becomes much easier to manage. When it is not, it can turn into a preventable pass/fail issue.
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