From our register we can see a number of very large charities, who we assume to have large legal departments, erring on the side of either caution or just doing the right thing. For that reason we have ensured that we hold the most recent charity register data from the Charities Commission within our platform. In terms of legal opinion, there are articles from legal professionals who also seem to feel that many charities and their subsidiaries are subject to section 54 compliance. We've linked to one of them here as an example. We have no affiliation with this law firm and recommend that if you are a charity, you get your own independent advice on your status:
https://www.bdb-law.co.uk/blogs/charity-laws/3-the-modern-slavery-act-and-charities/
There is a legal opinion that if a charity is subject to the UK Goods and Services Act that they are also subject to the Modern Slavery Act if their turnover is above £36M. Often charities have trading subsidiaries in order to deal with this and the Government guidance on charities and trading explains this very well.