Under New Zealand’s recently proposed Bill, reporting entities – including many US-based multinationals – would be required to report on how they identify, address, mitigate, and remediate incidents of modern slavery in their operations and supply chains. So what are the key features of the new Bill and how does it differ from its predecessors.

On February 10, a new Bill proposing a Modern Slavery Act was introduced in New Zealand’s Parliament. Bill 242-1, jointly sponsored by National Party MP Greg Fleming and Labour Party MP Camilla Belich, represents a bipartisan consensus replacing bills they proposed in 2025.

New Zealand has been considering corporate modern slavery legislation on-and-off for several years. In 2022, the then-Labour government proposed legislation that would have imposed modern slavery due diligence and reporting requirements on subject companies. 

In 2025, competing modern slavery reporting bills were introduced. These bills would have required reporting similar to that required under other modern slavery transparency laws in Australia, California, Canada and the UK.

• National Party Bill: Lodged by Greg Fleming on May 22, 2025, proposing a NZ$50m ($30m) revenue threshold and civil penalties of up to NZ$600,000 ($357,000).
• Labour Party bill: Lodged by Camilla Belich on July 17, 2025, also proposing a NZ$50m ($30m) threshold but with lower civil penalties of NZ$200,000 ($119,000), and the creation of an Anti-Slavery Commissioner.

Both bills were subsequently withdrawn to make way for the new bipartisan Bill.

The new Bill bypassed the usual “biscuit tin” ballot process for member’s bills by obtaining support from 61 non-executive MPs.

Reporting entities

The Bill captures both New Zealand-organized and foreign entities that carry on business in New Zealand, with annual consolidated revenue in the reporting period of NZ$100m ($59.5m). An entity also would be a reporting entity if it controls an entity that meets the foregoing criteria (the Canadian Act has a similar construct). 

The monetary threshold under the Bill is double that in the 2025 bills.

Modern slavery statement requirements

Content 

Similar to the 2025 bills, reporting entities would be required to produce an annual modern slavery statement. The statement would be required to include the following information:

• The name of the reporting entity and a description of its structure, operations, and supply chains (both domestic and international), including any entities owned or controlled by the reporting entity.
• A description of any modern slavery incident that has occurred within the operations and supply chains of the reporting entity and any entities it owns or controls.
• A description of any known or anticipated risks of modern slavery occurring within the operations and supply chains of the reporting entity and any entities it owns or controls.
• A description of the actions taken by the reporting entity and any entities it owns or controls to assess, prevent, address, mitigate, and remediate modern slavery and risks of modern slavery occurring, including due diligence and remediation processes.
• Details of the number of complaints made to the reporting entity in relation to modern slavery and any measures taken to investigate the complaints and to provide remediation for any incidents of modern slavery identified within the reporting entity’s operations and supply chains.
• A description of how the reporting entity assesses the effectiveness of the actions described in the two immediately preceding bullet points, and how any related processes or policies are being continually improved.
• A description of any training the reporting entity provides to identify modern slavery to its employees, the employees of entities it owns or controls, and the employees of any entities in its supply chain.
• A description of any consultation undertaken by the reporting entity with its employees, those of its controlled companies, and employees of entities in its supply chain.
• Any other prescribed information.

These are the same criteria as in the 2025 bills.

Reporting period: The reporting period would be the 12-month period from April 1 to March 31 of the preceding year. The reporting period would not be tied to the reporting entity’s fiscal year.

Signature: The modern slavery statement would need to be signed by a director or the equivalent of the reporting entity.

Publication: The modern slavery statement would need to be published on the reporting entity’s website and remain there until it is replaced by the following year’s statement. It also would need to be submitted for publication on an online government register within six months after the end of the reporting period.

Enforcement

Many of the current modern slavery reporting laws have been criticized for having weak enforcement mechanisms. The Bill seeks to address this through entity and individual fines and a bar from public procurement opportunities.

Reporting entities could be fined up to NZ$200,000 ($119,000) for breaches of reporting obligations. Under certain circumstances, a pecuniary penalty of up to NZ$600,000 ($357,000) could be payable. Convictions, orders and penalties would be required to be reported in the public register. Penalties for noncompliance were capped at NZ$200,000 ($119,000) under the Labour Party bill and NZ$600,000 ($357,000) under the National Party bill.

Persons who knowingly make a false or misleading statement or knowingly provide false or misleading information in a modern slavery statement also could be liable for a fine of up to NZ$200,000 ($119,000). The 2025 bills also contemplated fraud-based liability. 

If a reporting entity is convicted of an offense under the Act, a director or other senior manager could also be held personally liable if they authorized, permitted, or consented to the offense or knew or could reasonably be expected to have known that the offense was being committed and they failed to take all reasonable steps to prevent or stop it.

Entities convicted of offenses generally would be excluded from government procurement. This is a new addition not in the 2025 bills.

Anti-Slavery Commissioner provision jettisoned

Unlike the 2025 Labour Party bill, the new Bill does not seek to establish an Anti-Slavery Commissioner. However, the Bill’s sponsors have indicated that future consideration may be given to establishing this role through the Human Rights Commission.

Timeline and next steps

The Bill sponsors have stated their aim is to secure passage of the Bill before New Zealand’s general election on November 7, 2026. The Bill will now proceed through the customary legislative process, including select committee consideration and public submissions.

If enacted, the Act would come into force six months after Royal Assent. Based on this timeline, the first reports may be due in 2028.