What is New Zealand's proposed Modern Slavery Bill and how did it progress through Parliament?

New Zealand's proposed Modern Slavery Bill has bipartisan support and passed its first reading in Parliament. It was co-sponsored by Greg Fleming MP (ACT Party) and Camilla Belich MP (Labour), creating a cross-party partnership that enabled the legislation to bypass the standard members' ballot under Standing Order 280. The bipartisan approach and Prime Ministerial support have accelerated the Bill's progress significantly. The proposed regime is broadly aligned with Australia's Modern Slavery Act framework but introduces more prescriptive reporting obligations and potential penalties for non-compliance.

What is the revenue threshold for reporting under the NZ Modern Slavery Bill and who does it apply to?

The obligation to report applies to New Zealand entities (and their ultimate parent companies) carrying on business in New Zealand with consolidated revenue of NZD 100 million or more. In other major currency equivalents, the threshold is approximately USD 56 million, GBP 42 million, EUR 50 million, or AUD 80 million. The obligation applies not only to New Zealand-based entities, it will also be particularly relevant for all banks and insurers operating in New Zealand via a branch mechanism, organisations doing business with large businesses in New Zealand, and investors in New Zealand. The dual obligation means that where an NZ entity meets the threshold, the reporting obligation also falls on its global ultimate parent, wherever that parent is domiciled.

What personal liability provisions does the NZ Modern Slavery Bill introduce for directors?

The NZ Modern Slavery Bill introduces personal liability for directors and those involved in preparing modern slavery statements that are misleading, or where a statement is not filed or made available as required. This goes beyond the reporting obligations in Australia's existing Modern Slavery Act, which does not currently impose personal liability on individual directors or statement preparers. For global boards with New Zealand-connected entities, this provision means that NZ modern slavery compliance cannot be treated solely as a corporate reporting exercise, it creates individual accountability for those overseeing and preparing disclosures.

What practical steps should organisations take now to prepare for the NZ Modern Slavery Bill?

Organisations should: determine whether any entities in their group carry on business in New Zealand and whether consolidated group revenue meets or is likely to meet the NZD 100 million threshold; identify who the global ultimate parent entity is for NZ reporting purposes, as the dual obligation means that parent will also be in scope; assess whether existing modern slavery reporting programmes (including Australian MSA statements) would satisfy the NZ Bill's more prescriptive content requirements, or whether gap-filling is needed; review director and governance accountability frameworks to understand who would be personally liable for misleading statements or non-filing; and begin building or strengthening supply chain risk assessment and due diligence processes that can generate the evidence a more prescriptive regime will require, rather than waiting for enactment.

Home » Resources » Understanding New Zealand’s Modern Slavery Bill: Local and Global Implications [NZPEF]

Understanding New Zealand’s Modern Slavery Bill: Local and Global Implications [NZPEF]

Amanda Ong
September 25, 2026

New Zealand’s proposed Modern Slavery Bill has bipartisan support and is progressing through Parliament following a successful first reading. This session will provide a practical overview of the Bill and its implications for businesses with operations or customers connected to New Zealand.

The proposed regime is broadly aligned with the Australian framework but introduces more prescriptive reporting obligations and potential penalties for non-compliance, including personal liability for directors and those involved in preparing statements that are misleading or where a statement is not filed or made available.

Importantly, the reporting obligation sits with both the New Zealand entity and its ultimate parent company in relation to the entire group, regardless of where that parent is domiciled.

Which organisations will this be relevant for?

The obligation to report will apply to the NZ entity and its ultimate parent, regardless of where it is domiciled, where the entity carrying on business in NZ has consolidated revenue of NZD 100 million / USD 56 million / GBP 42 million / EUR 50 million / AUD 80 million or more. In addition to New Zealand based entities, the session will have particular references for:

All banks and insurers operating in New Zealand via a branch mechanism

Organisations doing business with large businesses in New Zealand

Investors in New Zealand

Who should join?

This session will be particularly relevant for the following groups:

Legal and compliance

ESG and sustainability

Risk and internal audit

Procurement and supply chain management

Corporate governance and company secretariat

This session will explore:

An overview of New Zealand’s proposed Modern Slavery Bill and its bipartisan path through Parliament

How the proposed regime compares with Australia’s existing framework, and where it goes further

The dual reporting obligation between the NZ entity and its global parent company

Personal liability provisions for directors and those preparing modern slavery statements

Practical steps organisations should be taking now to prepare for a more formalised compliance regime

Speakers:

Greg Fleming, Member of Parliament for Maungakiekie, New Zealand Government
Abigail McGregor, Partner, Norton Rose Fulbright Australia
Grace Do, Special Counsel, Norton Rose Fulbright Australia
Ian Gallagher, Senior Business Development Manager, Ethixbase360 (Moderator)

compliance, Ethixbase360, riskmanagement, supply chain, Third Party Risk Management

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Understanding New Zealand’s Modern Slavery Bill: Local and Global Implications [NZPEF]

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