A Global Movement Reaches New Zealand
The Bill mandates that private and public entities with annual revenue exceeding NZD 50 million must submit a modern slavery statement disclosing how they identify, address, mitigate, and remediate risks of trafficking and modern slavery within their operations and supply chains. A clause relating to high-risk entities also allows for threshold adjustment for businesses operating in particularly vulnerable sectors, meaning even smaller companies in high-risk industries may be captured. Businesses covered by the Bill will be expected to map their supply chains, identify risks, and publish detailed annual statements on how they are mitigating exploitation. This is explicitly not intended to be a box-ticking exercise. Disclosures must cover risk assessment processes, actions taken to prevent and address modern slavery, and stakeholder engagement with suppliers, NGOs, and other relevant parties. The Bill also proposes the establishment of an Independent Anti-Slavery Commissioner to monitor progress and provide accountability — mirroring a similar mechanism in Australia. Additionally, it includes updates to the Crimes Act to strengthen legal provisions related to trafficking in persons, align with the Palermo Protocol, and resolve a specific gap in prosecuting child trafficking cases. A publicly accessible register for modern slavery statements is also proposed to enhance transparency across the business community.
The proposed legislation introduces mandatory reporting thresholds, an independent oversight body, and enforceable disclosure requirements for businesses operating in New Zealand.
The Bill mandates that private and public entities with annual revenue exceeding NZD 50 million must submit a modern slavery statement disclosing how they identify, address, mitigate, and remediate risks of trafficking and modern slavery within their operations and supply chains. A clause relating to high-risk entities also allows for threshold adjustment for businesses operating in particularly vulnerable sectors, meaning even smaller companies in high-risk industries may be captured. Businesses covered by the Bill will be expected to map their supply chains, identify risks, and publish detailed annual statements on how they are mitigating exploitation. This is explicitly not intended to be a box-ticking exercise. Disclosures must cover risk assessment processes, actions taken to prevent and address modern slavery, and stakeholder engagement with suppliers, NGOs, and other relevant parties. The Bill also proposes the establishment of an Independent Anti-Slavery Commissioner to monitor progress and provide accountability — mirroring a similar mechanism in Australia. Additionally, it includes updates to the Crimes Act to strengthen legal provisions related to trafficking in persons, align with the Palermo Protocol, and resolve a specific gap in prosecuting child trafficking cases. A publicly accessible register for modern slavery statements is also proposed to enhance transparency across the business community.
The Bill is progressing through New Zealand's parliamentary process, but businesses should not wait for Royal Assent before beginning their compliance preparations.
The Bill is currently in its consultation and review phase as a Member's Bill and will need to pass through multiple stages in New Zealand's legislative process — including potential select committee hearings and public input — before it becomes law. Its introduction has been proposed by leveraging a 2023 amendment to the Standing Orders of the House of Representatives, which allows non-executive bills with majority support from 61 non-executive members to bypass the ballot and go directly to a first reading. If enacted, most provisions of the Bill will come into force six months after receiving Royal Assent. That compressed timeline means businesses may have less than a year to get their due diligence systems fully in place. Although the Bill is not yet law, the direction is clear: companies will be held accountable for exploitation in their supply chains, and acting early will not only reduce future compliance risks but will demonstrate ethical leadership. Consultation on the Bill is expected to include engagement with survivors to ensure survivor-informed perspectives are incorporated, as well as engagement with iwi to ensure Te Tiriti o Waitangi and a Te Ao Māori perspective are fully integrated into the final legislation.
Compliance with New Zealand's Modern Slavery Bill requires proactive supply chain mapping, risk assessment, and structured reporting — and FRDM is ready to help.
New Zealand's proposed law reflects a global shift: ethical sourcing is no longer optional — it is becoming enforceable. For businesses operating in or trading with New Zealand, the time to build robust human rights due diligence systems is now, before the compliance clock starts ticking. Those that invest in supply chain transparency early will be better positioned to meet regulatory requirements, satisfy investor expectations, and protect their reputations. At FRDM, the platform is purpose-built to help companies meet regulatory obligations like New Zealand's Modern Slavery Bill and go beyond mere compliance to build ethical, resilient supply chains. FRDM has helped global banks, retailers, manufacturers, and government agencies take control of their supply chain risk, and stands ready to support New Zealand entities — and their global trading partners — through this regulatory transition.
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