New Zealand is poised to introduce mandatory modern slavery reporting legislation requiring businesses with revenue over $100 million to disclose how they manage modern slavery risks across their operations and supply chains. The regime will also capture overseas companies carrying on business in New Zealand during a reporting period, as well as companies that directly or indirectly control a reporting entity — including parent companies.
The anticipated Modern Slavery Bill will align with global efforts to detect and address forced labour and other abusive working conditions, which businesses should be aware of when assessing risk in their operations and suppliers. The International Labour Organization’s 2025 Indicators highlight how people can be coerced or trapped through vulnerabilities, deception, movement and social restrictions, violence and threats, document and wage retention, debt, abusive conditions, and excessive working hours.
For many businesses, the Bill won’t be entirely new. Australia’s Modern Slavery Act is already in force, with mandatory reporting, public scrutiny and increasing regulatory and stakeholder expectations — offering a clear preview of where NZ is heading.
Modern slavery under the proposed New Zealand Bill is broadly defined as:
- An offence under section 98, 98AA, 98D, or 207A of the Crimes Act 1961
- Dealing in slaves
- People smuggling and trafficking
- Dealing in people under 18 for sexual exploitation, removal of body parts, or engagement in forced labour
- Coerced marriage or civil union
- The worst forms of child labour
- Debt-bondage or serfdom
- Forced or exploitative labour:
- Servitude
- Slavery
The key requirement of the draft Bill proposes that mandated entities disclose the modern slavery risks in their business and how these are managed via an annual Modern Slavery Statement. The Statement must outline the entity’s structure, operations and supply chains; disclose any modern slavery incidents and identified risks; detail the actions and due diligence undertaken to address them — including complaints processes, remediation, effectiveness assessments, training and consultation — and include any additional information required by regulation. Specifically, the Statement must include:
- Entity name and overview of structure, operations and supply chains (including owned/controlled entities).
- Modern slavery incidents identified in operations or supply chains as well as known or potential modern slavery risks
- Number of modern slavery-related complaints received.
- Actions taken to assess and address risks and incidents, including due diligence and remediation.
- How the effectiveness of those actions is evaluated.
- Modern slavery training provided to employees and relevant supply chain participants.
- Consultation undertaken in preparing the Statement.
- Any other information required by regulation.
Unlike Australia — where there are currently no financial penalties for non-compliance (though reforms are under consultation) — the proposed New Zealand Bill adopts a stricter enforcement model. If a reporting entity fails to prepare or publish a compliant annual Statement, or knowingly includes false or misleading information, it may face a fine of up to NZD $200,000. In addition, the High Court may order a non-government reporting entity to pay a civil penalty to the Crown of up to NZD $600,000.
Why is the Bill important?
The New Zealand legislation is approaching fast – it’s not hypothetical. Early preparation reduces compliance risk and future cost.
Australian Modern Slavery requirements already affect trans-Tasman and supply-chain-linked businesses under the Australian Modern Slavery Act and this is expected to become more rigorous in the future with a consultation to further strengthen the Act currently underway.
Modern Slavery statistics at a glance
- Police stated there were 19 ongoing investigations in New Zealand in 2024 with a further 31 in 2025 (RNZ).
- In 2024-25, the Australian Federal Police received 420 reports of human trafficking and modern slavery – a 10% increase versus the previous year and nearly doubled compared to five years ago (https://www.antislaverycommissioner.gov.au).
- According to World Vision, New Zealand imported $7.9B of goods considered risky due to their association with child labour.
How to prepare:
Entities, whether mandated to report on Modern Slavery or not are coming under increased scrutiny from stakeholders and investors around their labour practices, due diligence, and transparency. The proposed New Zealand Bill is not simply a compliance exercise. It is about running a socially sustainable business, risk management, commercial resilience, and maintaining access to customers, capital and international markets. As seen in Australia and other jurisdictions, regulators and customers are increasingly asking not just for statements of intent, but for evidence of a structured, repeatable process.
Organisations that act early will be better positioned to meet regulatory requirements, respond to customer questionnaires, and demonstrate credible oversight of labour risks across their operations and supply chains.
The key question is no longer whether scrutiny will increase — but whether your organisation is prepared for it.
Below are some tips to get started on preparing for Modern Slavery legislation in New Zealand.
1. Establish Governance
- Outcome: Clear ownership and governance structure.
2. Map Operations & Supply Chains
- Outcome: A documented supplier map.
3. Conduct a Risk-Based Assessment
- Outcome: Risk-rated supplier and operational profile.
4. Prioritise & Engage
- Outcome: Validated risks and identified gaps.
5. Address & Embed Controls
- Outcome: Documented mitigation framework.
6. Monitor & Report
- Outcome: Modern Slavery Statement and any other reporting as required.
A credible Modern Slavery Statement demonstrates a clear, repeatable process and year-on-year improvement — not perfection on day one.
How Tadpole can help
If your business operates in New Zealand or Australia or you have suppliers which may fall in scope, now is the time to prepare frameworks, due diligence processes, and reporting capabilities.
Tadpole has a practical methodology for each step outlined above to ensure thorough preparedness and meaningful reporting.
We can help you understand the detailed requirements and build compliant, practical reporting and risk mitigation strategies that align with both New Zealand’s evolving regime and Australia’s established framework.
If you’re wondering what all this means for your business, contact Tadpole Director, Allan Birch (+64 21 930 992 / allan@tadpole.co.nz) to discuss where your organisation stands and your best next steps.
Disclaimer: This article provides general information only and does not constitute legal advice; entities should seek independent legal advice tailored to their specific circumstances.