The Modern Slavery Bill passed its first reading earlier this week, marking a significant development for New Zealand businesses subject to the proposed framework.
The bill, if enacted in its current form, would attempt to reduce modern slavery by imposing new reporting obligations. For entities subject to the regime, that will likely require significant new processes to ensure that the mandatory annual reports are compliant and accurate, to avoid new penalties and other enforcement consequences proposed under the bill - including potential personal liability for directors and others involved in producing the disclosures.
For businesses likely to be above the financial threshold established by the bill, early preparation (and active engagement in the consultation) will be key. Submissions are due by 28 May 2026.
Summary of the bill
As discussed in our previous article (here) the bill will require reporting entities to prepare a modern slavery statement for each reporting period, submit it to a designated registrar within six months after the end of the reporting period, and to publish the statement on their own website. The scope includes any entity with consolidated revenue of more than NZ$100 million that is either a New Zealand entity or an overseas company carrying on business in New Zealand. Surprisingly, the proposed regime also captures entities that control other reporting entities (e.g. parent companies).
The content requirements for a modern slavery statement are relatively detailed. A modern slavery statement must contain a specified list of information, including details of the entity’s structure, operations and supply chains, any modern slavery incidents that have occurred, known or anticipated risks, and actions taken to assess, prevent, address, mitigate and remediate risks. There are also requirements to disclose the number of complaints received, investigation and remediation measures, as well as details of training, consultation and how effectiveness is assessed and improved over time.
While the proposed New Zealand model was generally based on the Australian regime, it diverges in several unusual and technical respects. For example, the specific obligation in New Zealand to report on modern slavery “incidents” in annual statements, or to detail complaints relating to modern slavery, are not features of the Australian framework. The New Zealand bill also introduces some subtle but possibly significant wording changes - such as requiring disclosure of “known or anticipated risks” rather than simply “risks” of modern slavery, which create uncertainty as to what more is required in New Zealand than for equivalent Australian reports. Most notably, the New Zealand regime imposes financial penalties (fines of up to NZ$200,000 or civil penalties of up to NZ$600,000) and the prospect of personal liability for directors and managers, which do not feature in the Australian legislation. These differences are likely to make the New Zealand model more complex and onerous in practice.
Those differences may create unexpected practical challenges for any entities with multinational operations familiar with the current Australian requirements. Businesses in New Zealand may need additional internal complaint-handling pathways, clearer investigation protocols and additional processes to identify when an issue becomes a reportable “incident”.
Key takeaways from the first-reading debate
The first reading was marked by a strong sense of cross-party cooperation and a recognition of the bill’s significance as a step forward for New Zealand’s response to modern slavery. Camilla Belich, who moved the bill, described it as “an historic day for the New Zealand Parliament” noting that the proposed regime is “the right thing to do”.
The ACT Party expressed a more sceptical stance and questioned whether the bill would achieve its intended outcomes or simply create additional compliance burdens. Laura McClure expressed concern that the reform may ultimately comprise “filling in forms and ticking boxes” and suggested that existing slavery offences under the Crimes Act were a more effective way of addressing the real challenges of slavery and exploitation.
Positively, many speakers stressed the importance of the select committee process in refining the bill and acknowledged the need for consistency with comparable overseas regimes and minimising unnecessary duplication for businesses already reporting in other jurisdictions. In our view, the current bill is ambitious and more onerous than Australia’s regime. The bill should be carefully considered to ensure it is appropriately calibrated to achieve its intentions without creating an undue compliance burden.
Next steps – submissions due by 28 May 2026
For businesses likely to be above the thresholds, the key priority is to start preparing early. The bill would require reporting on structure, operations, supply chains, incidents, risks, complaints, remediation, training and effectiveness, so organisations will need good processes to meet the proposed obligations. Based on the likely legislative timetable, the first modern slavery statements are likely to be due in 2028, covering reporting periods from 1 April 2027 to 31 March 2028 (or 1 July 2027 to 30 June 2028 for government agencies).
That may sound like a long runway, but in practice there is much to be done within that timeframe. Many businesses may need to make significant changes to their supply chain diligence processes and internal reporting frameworks. Early engagement and preparation will be essential to avoid last-minute challenges and to ensure that organisations are ready to meet the requirements when they come into force.
In addition, it will also be important for affected businesses to actively engage in the consultation process, and to submit before the 28 May 2026 deadline, to help ensure the regime is workable in practice and appropriately calibrated.
We have been tracking these developments closely and will continue to monitor the bill as it moves through the select committee process. In particular, we are focused on the practical implications for large businesses, including governance, reporting design, incident escalation, supply chain diligence and alignment with offshore compliance frameworks.
If you would like to discuss what the proposed regime may mean for your organisation, or if you would like to receive a recording of our recent webinar on modern slavery which explores the detail of the bill and some of the challenges it creates, please contact your Bell Gully advisor.
Disclaimer: This publication is necessarily brief and general in nature. You should seek professional advice before taking any action in relation to the matters dealt with in this publication.
