Modern slavery reporting in New Zealand

Modern slavery legislation is moving forward in New Zealand, and the direction of travel is already clear.

Introduced to Parliament in early 2026, the proposed Modern Slavery Bill has strong bipartisan backing and passed its first reading on 29 April with 112 votes in favour. While the Bill is still in its consultation phase, it signals a clear shift towards more structured, enforceable reporting expectations.

The Select Committee is expected to report back by the end of August 2026. That leaves a window for input, but also a limited runway for organisations to prepare.

A broad scope will bring more organisations into focus

As currently proposed, the legislation will apply to organisations with more than NZD 100 million in consolidated annual revenue.

The definition of an ‘entity’ is intentionally broad. It extends beyond companies to include trusts, partnerships, and Crown entities. Current estimates suggest around 700 organisations could fall within scope.

Reporting is expected to cover both domestic and international operations, as well as supply chains.

Reporting expectations for risk ownership

The proposed approach goes beyond disclosing known or identified cases.

Organisations will be expected to:

• Identify and disclose potential modern slavery risks 
• Explain how those risks are prioritised
• Demonstrate how risks are managed over time

This places greater emphasis on forward-looking risk assessment rather than retrospective reporting.

Accountability is becoming more clearly defined 

Although the Bill does not prescribe specific due diligence steps, but expectations around what organisations need to demonstrate are becoming more defined.

Entities will need to clearly explain how modern slavery risks are identified, what actions are taken to prevent and address harm, and how remediation is handled where issues are found. In practice, this points to more structured approaches to supplier risk assessment, stronger governance, and clearer internal ownership. Data quality and consistency will also come under closer scrutiny.

At the same time, the proposed regime moves beyond voluntary disclosure. Financial penalties, potential liability for directors and senior management, and exclusion from public procurement in cases of serious or repeated breaches are all in scope. While the Bill does not introduce new criminal offences, it reinforces a shift towards transparency that is backed by enforceable consequences.

How does this compare to Australia?

New Zealand’s proposal builds on existing frameworks, while introducing additional expectations. 

Compared to approaches such as Australia’s, organisations will be expected to go further in how they report and evidence their activity. This includes greater transparency around complaints and grievances, clearer assessment of whether actions taken are actually effective, and more emphasis on training and internal consultation as part of ongoing governance.

What should organisations be doing now?

At this stage, organisation can take practical steps and consider engaging with the Select Committee consultation process, carrying out an early gap analysis against the proposed requirements, and ensuring there is clear awareness at Board and Executive level around governance and risk ownership.

Early preparation makes it easier to respond as details are finalised. For many, this will involve reviewing how supply chain risks are identified, assessed, and monitored in practice.

The direction is consistent with a broader global trend. Expectations around transparency, risk management, and accountability are increasing, with less tolerance for informal or reactive approaches.

For organisations preparing for these changes, the challenge is often less about awareness and more about execution.

Building a clear view of supply chains, strengthening procurement processes, and maintaining reliable data across operations are all areas that require consistency over time. EiQ supports organisations in identifying and prioritising risk, mapping supply chains, and embedding ongoing monitoring into day-to-day operations.