4 February 2026
Bipartisan deal accelerates new modern slavery regime for New Zealand
A bipartisan Modern Slavery Bill intends to introduce a modern slavery reporting regime for New Zealand. The regime will apply to entities with consolidated annual revenue over NZD100 million. If enacted before the general election this year, the modern slavery reporting regime is likely to become operational in early 2027, with first reporting obligations falling in the 2028 reporting year.
New Zealand’s proposed modern slavery law doesn’t just copy overseas models. It quietly goes further in ways global businesses need to understand.
As jurisdictions like Australia, the UK and the EU take divergent approaches to modern slavery compliance, New Zealand’s proposed regime introduces penalties, incident reporting and ministerial oversight that materially change how companies manage risk within New Zealand business operations and across borders. Understanding what this legislation does differently, and what that means in practice, makes it essential reading even for businesses already reporting under overseas regimes.
Key features of the Bill
The Bill will create New Zealand’s first mandatory framework for reporting on modern slavery. Key features include:
- Mandatory annual modern slavery reporting for large businesses and entities operating in New Zealand with consolidated annual revenue over NZD100 million.
- Publication of modern slavery statements in an online, publicly searchable register, enhancing transparency and accountability.
- Reporting criteria familiar to those reporting under the Australian modern slavery regime, including descriptions of:
- the entity and its supply chains;
- any known or anticipated risks of modern slavery within its operations and supply chain;
- the actions taken by the entity to address those risks, including due diligence and remediation processes;
- how the entity has assessed the effectiveness of its actions in dealing with modern slavery; and
- consultation with, and training for, employees on modern slavery.
- Additional reporting criteria over and above that required in Australia include reporting on any modern slavery incidents that have occurred, complaints of modern slavery received, and the measures taken to investigate them.
- A formal role for the New Zealand Human Rights Commission, including regular legislative reviews and consideration of an Anti-Slavery Commissioner in the future.
- Enforcement mechanisms, including:
- fines for failure to report, or for reporting false or misleading statements; and
- civil penalties, public naming, potential liability for directors and senior managers, and loss of eligibility for government funding and procurement.
- Strengthened reporting to Parliament, including specific annual reporting in a ministerial report, mandatory guidance on victim identification and referral, and ongoing review of the adequacy of victim protections and services.
- Inclusion of the public sector in reporting requirements.
Why this matters
New Zealand’s journey toward modern slavery legislation has spanned years of consultation, advocacy and stalled attempts.
The prevalence of modern slavery continues to increase globally. While risks arise in the goods and services New Zealand businesses import, there is also risk of exploitation of workers within New Zealand and a need for effective victim identification.
Business, investor and civil society groups have publicly supported modern slavery legislation, citing both human rights imperatives and material commercial risk for New Zealand if supply chain transparency remains weak. There has also been longstanding criticism that New Zealand has lagged behind key trading partners.
The Bill defines ‘modern slavery’ for the purposes of the regime and aims to provide consistent guidance for businesses. It also seeks to create a more level playing field by putting suppliers on notice that abnormally low prices may reflect labour exploitation, addressing the competitive disadvantage faced by providers who pay lawful wages and comply with employment standards.
The absence of penalties in some overseas modern slavery regimes has led to criticism that reporting can become a box-ticking exercise. New Zealand’s Bill responds to that experience by introducing enforcement mechanisms, including penalties for non-compliance, potential director and senior manager liability, and clearer disclosure of complaints and incidents. It also introduces reporting to the responsible Minister and consolidated ministerial reporting to Parliament. Taken together, these measures position the regime as a mechanism of public accountability, rather than a purely market-driven transparency exercise.
What is missing from the Bill?
Notably absent from the consolidated Bill are provisions that were included in earlier legislative drafts:
- Enhanced victim protection and support frameworks, such as guaranteed access to emergency accommodation, legal services and rehabilitation.
- A formal due diligence obligation, requiring entities not only to report but to actively prevent and remedy modern slavery risks.
- Lower thresholds: the reporting threshold has increased from the NZD50 million revenue level previously proposed to NZD100 million, significantly reducing the number of entities captured.
While the Bill stops short of requiring active due diligence or embedding stronger victim protections, it marks a significant national step forward, delivered through cross-party cooperation.
Practical next steps for businesses
Depending on the enactment date, first reporting obligations are anticipated to fall in 2028, with the initial reporting period covering activity undertaken in 2027.
There are practical steps businesses can take now to prepare. These processes take time, so businesses that do not already have them in place should start early:
- Confirm whether the business may need to report, including whether it operates in New Zealand and has consolidated annual revenue exceeding NZD100 million (including group entities).
- Identify joint venture or group reporting options (the Bill allows joint statements in some circumstances).
- Allocate board-level oversight of modern slavery reporting (for example, an audit, risk, sustainability, or people and culture committee).
- Appoint a senior responsible owner (potentially in legal, risk, sustainability or human resources) and identify contributors across the business. Modern slavery risk does not sit in one area, so input is typically required from business operations, legal and risk, sustainability, human resources, procurement and health and safety.
- Start documenting core business activities, goods and services purchased, countries of sourcing, use of labour hire, migrant labour and subcontractors. Focus initially on tier-one suppliers and areas commonly associated with higher risk. When assessing modern slavery risk, businesses commonly consider four intersecting risk categories: sector and industry risks; product and services risks; geographic risks; and entity risks.
- Review policies and contractual processes. For example: does the business have appropriate policies relating to modern slavery? Do contracts include supplier engagement and termination processes for labour violations?
- Businesses should ensure effective grievance mechanisms are in place to capture modern slavery‑related complaints and document how concerns are investigated and addressed. This includes reviewing whether existing reporting frameworks and grievance mechanisms are safe to use, accessible to all workers and whether they are used in practice. Non-use may itself indicate an ineffective system.
- Begin raising internal awareness of modern slavery, including at board governance level.
Importantly, the legislation does not require businesses to trace full supply chains from day one. It encourages a proportionate approach grounded in the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, starting with strong policies and procedures and a focus on the most salient modern slavery risks.
Compliance with other jurisdictions
Across many jurisdictions, modern slavery legislation and mandatory human rights due diligence remain the subject of active reform discussions rather than settled regulatory frameworks.
New Zealand’s more prescriptive reporting framework may allow businesses to develop a single, robust modern slavery narrative that can be adapted to meet Australian, UK, Canadian and other transparency-based regimes, while also generating the supply chain mapping, incident reporting and governance evidence increasingly expected in enforcement-based systems.
This is particularly relevant given the EU Forced Labour Regulation, which introduces a market access ban from December 2027. It would prohibit products made wholly or partly with forced labour from being placed on, made available in, or exported from the EU market, regardless of where the forced labour occurs and across all sectors, including online sales.
By embedding clearer expectations around risk identification, complaints and incidents, and documented action, New Zealand’s proposed framework may reduce duplication and compliance friction for internationally active businesses and help position them to evidence due diligence and good-faith compliance under the EU’s investigatory, risk-based enforcement model.
How DLA Piper can support
DLA Piper advises clients on modern slavery and human rights risk compliance, including modern slavery reporting, human rights due diligence, risk assessments, remediation strategies and board-level governance.