New Zealand’s proposed modern slavery reporting regime has taken an important step forward. The Education and Workforce Committee has recommended, by majority, that the Modern Slavery Bill be passed, with all proposed amendments supported unanimously.

The Bill has not yet become law. As at 28 September 2026, it is awaiting its second reading, when Parliament will debate and vote on the Bill and the Select Committee’s recommended changes. View the Bill’s progress through Parliament.

What would the Bill do?

The Bill would establish a public reporting regime aimed at reducing modern slavery risks in organisations’ operations and supply chains, while encouraging due diligence and increasing awareness and support for victims.

“Modern slavery” is broadly defined. It would include slavery, trafficking in persons, servitude, forced or exploitative labour or services, the worst forms of child labour, and certain conduct that would constitute an offence under New Zealand law.

The central obligation would fall on New Zealand entities, and overseas companies carrying out business in New Zealand, that meet the proposed revenue threshold. Those organisations would have to prepare a modern slavery statement for each reporting period, obtain board approval, have the statement signed by an authorised person, and provide it to the Registrar within six months after the end of the reporting period. Statements would be published on a central public register.

What would a modern slavery statement cover?

A reporting entity would need to explain:

• its structure, operations, and domestic and international supply chains;
• any modern slavery identified in those operations or supply chains;
• known or anticipated modern slavery risks;
• the due diligence steps taken to identify, prevent, address, mitigate, and remediate those risks;
• complaints received and the measures taken to investigate them;
• how it measures the effectiveness of its actions;
• relevant training provided to its own workforce, subsidiaries, and people working within its supply chains; and
• consultation with employees and subsidiaries.

The Bill is primarily a reporting and transparency regime, rather than a comprehensive mandatory due diligence regime. However, its reporting requirements are likely to place organisations under real pressure to demonstrate that they have meaningful systems in place, rather than simply producing a policy or annual statement. The Committee has also left open the possibility of a broader due diligence regime being considered during a future review.

Who would be covered?

The Select Committee has retained the proposed threshold of $100 million in annual revenue. However, it recommends that an entity should meet that threshold in each of its two preceding accounting periods before becoming subject to mandatory reporting. The report estimates that around 1,250 New Zealand entities may currently meet the threshold.

Corporate structuring would not provide an easy route around the regime. An entity could qualify where its combined revenue with one or more subsidiaries reaches the threshold, and groups would be able to submit a joint statement covering relevant subsidiaries.

The threshold could be increased by regulation to reflect increases in the Consumers Price Index, but could not be reduced by regulation. The Committee considered that any broader change affecting who may face civil or criminal liability should be made through primary legislation.

Smaller businesses may still feel the impact

Businesses below the $100 million threshold would not have a mandatory reporting obligation under the Bill. However, many are likely to be affected indirectly.

Large customers will need information from their suppliers to understand and report on risks throughout their domestic and international supply chains. Smaller suppliers may therefore be asked to complete questionnaires, trace the origin of goods or materials, provide contractual assurances, participate in audits or training, and supply evidence of their employment and procurement practices.

This concern was raised particularly strongly in ACT New Zealand’s differing view. ACT opposed the Bill, arguing that regulatory costs could flow down supply chains and affect smaller businesses despite their falling below the statutory threshold.

For many smaller suppliers, modern slavery readiness may therefore become a commercial expectation before it becomes a direct legal requirement.

What did the Select Committee change?

The Committee proposed several significant changes designed to improve workability and align the regime more closely with Australia and other New Zealand corporate reporting regimes.

More time to prepare

The Bill would still come into force six months after Royal Assent. However, the first reporting period would be the first full 12-month reporting period beginning after commencement. The Committee says this would generally leave around 24 months between enactment and the first statements falling due, and potentially up to 36 months for some entities depending on their balance date.

Reporting aligned with balance dates

Instead of imposing a single statutory reporting year, statements would be due six months after each reporting entity’s own balance date. This should make the modern slavery process easier to integrate with existing governance and corporate reporting cycles.

Recognition of Australian statements

An entity that already prepares a statement under Australia’s Modern Slavery Act 2018 could provide that statement in New Zealand instead of preparing another one. Regulations could later recognise equivalent statements from other jurisdictions.

Group and voluntary reporting

Corporate groups would be able to submit joint statements. Organisations below the threshold could also report voluntarily, although a voluntary statement would need to meet the same substantive standards, obtain board approval, and be signed by an authorised person.

Protection for sensitive information

The revised Bill recognises that some information may be commercially sensitive, protected by privacy law, or unsuitable for publication. An entity could ask the Registrar not to publish particular information, although it would need to explain why. The Committee expects the Registrar to apply a high threshold before withholding information.

Information likely to prejudice law enforcement, an investigation, or the right to a fair trial would not need to be included.

Removal of duplicate website publication

The original Bill required organisations to publish statements on their own websites as well as submitting them to the central register. The Committee recommends removing that duplication, meaning publication on the register would be sufficient.

A more graduated enforcement model

The Registrar would be able to request information demonstrating compliance, require an explanation or remedial action, and publish details of continued non-compliance. An affected organisation could seek a review of a publication decision within 20 working days.

The Bill would also retain potentially significant liability. An individual who knowingly includes materially false or misleading information could face a fine of up to $200,000. Directors and senior managers could also face liability in specified circumstances. A reporting entity could face a pecuniary penalty of up to $600,000 for each relevant act or omission, subject to statutory defences including having taken all reasonable steps to comply.

No automatic ban on Crown funding

The original Bill proposed preventing Crown payments to entities convicted or penalised under the regime. The Committee recommends removing that proposal because of concerns about double jeopardy, existing contracts, uncertainty about implementation, and the absence of a route for a business to remediate and become eligible for funding again.

What did submitters say?

The Committee received 347 submissions and heard oral evidence from 69 submitters. The broader public engagement included a World Vision submission supported by more than 1,500 named individuals, more than 900 handwritten submissions from children through World Vision Advocacy Ambassadors, and views from more than 1,600 people gathered through Tearfund’s process.

The report records broad engagement with the Bill’s objective, but differing views about its design. Key themes included:

• support for stronger action and greater supply-chain transparency;
• calls for an independent anti-slavery commissioner;
• interest in a broader mandatory due diligence regime;
• concerns about implementation time and duplicated reporting;
• concern about commercial sensitivity, privacy, self-incrimination, and ongoing investigations;
• questions about personal liability for directors, managers, and other employees;
• concern about differing treatment of businesses and public bodies;
• the compliance burden on large organisations and smaller suppliers; and
• debate about whether reporting regimes produce sufficient practical benefits for victims.

The Committee has not recommended establishing an anti-slavery commissioner or a comprehensive due diligence regime at this stage. Instead, these matters must be considered as part of a review three years after commencement, followed by a further review five years later.

What should businesses do now?

The Bill may still change as it progresses through Parliament, but organisations should consider taking the following practical steps now:

1. Assess whether the threshold could apply, including revenue across subsidiaries and related group structures.
2. Map key supply chains, including labour providers, contractors, offshore suppliers, and higher-risk products or services.
3. Review recruitment and employment practices, particularly migrant worker arrangements, recruitment fees, document retention, deductions, accommodation, and subcontracted labour.
4. Review supplier contracts and procurement processes to determine whether they provide appropriate information, assurance, audit, and remediation mechanisms.
5. Create a reporting pathway so workers and suppliers can raise concerns safely and those concerns can be investigated.
6. Allocate governance responsibility, including who will gather information, assess risk, prepare the statement, and brief the board.
7. Keep evidence of the steps taken. The proposed regime will require more than a statement of good intentions. Organisations will need reliable information to support public representations about their supply chains.

Key takeaway

The immediate legal obligation would sit with organisations meeting the $100 million threshold. The practical impact is likely to be much wider. Customers, funders, tendering bodies, and larger organisations may increasingly expect suppliers of every size to show how they identify and manage labour exploitation risks.

Early preparation will give businesses time to identify gaps, improve supplier relationships, and put defensible reporting systems in place before statements become due.

Need support? If you would like help assessing whether the proposed regime may apply to your organisation, reviewing your employment and supplier practices, or developing a practical modern slavery readiness plan, please contact our workplace law team. Email admin@cmalaw.co.nz or phone 03 211 0153.

Disclaimer: This update provides commentary on employment law, health and safety and immigration topics, it should not be used as a substitute for legal or professional advice for specific situations. Please seek legal advice from your lawyer for any questions specific to your workplace.