What Is New Zealand's Modern Slavery Law?
Under the new law, companies will be required to be transparent and annually disclose the risks of modern slavery in their supply chains and operations. The law is expected to apply to all companies with an annual revenue over $20 million, which includes around 4,000 entities in New Zealand. Organizations operating in high-risk sectors may face additional obligations regardless of revenue threshold. Central to the proposed law is transparency. Companies meeting the revenue criteria will be required to produce an annual modern slavery statement covering several key areas: an overview of the organization's structure, including subsidiaries and supply chains; a risk assessment identifying modern slavery risks within operations and supply chains; a description of actions taken to prevent and address modern slavery; and details of engagement with suppliers, NGOs, and other stakeholders. The annual statement must be approved by the organization's board or governing body, ensuring accountability at the highest level of leadership. Organizations will need to share information about risks of forced labor at all levels of their supply chain — not just direct suppliers. A digital public register will be established to ensure transparency and public accessibility of these disclosures. Companies that fail to meet disclosure requirements face fines of up to $10,000, while those providing false or misleading information can face penalties up to $200,000.
The law targets thousands of entities and mandates detailed, board-approved annual modern slavery statements.
Under the new law, companies will be required to be transparent and annually disclose the risks of modern slavery in their supply chains and operations. The law is expected to apply to all companies with an annual revenue over $20 million, which includes around 4,000 entities in New Zealand. Organizations operating in high-risk sectors may face additional obligations regardless of revenue threshold. Central to the proposed law is transparency. Companies meeting the revenue criteria will be required to produce an annual modern slavery statement covering several key areas: an overview of the organization's structure, including subsidiaries and supply chains; a risk assessment identifying modern slavery risks within operations and supply chains; a description of actions taken to prevent and address modern slavery; and details of engagement with suppliers, NGOs, and other stakeholders. The annual statement must be approved by the organization's board or governing body, ensuring accountability at the highest level of leadership. Organizations will need to share information about risks of forced labor at all levels of their supply chain — not just direct suppliers. A digital public register will be established to ensure transparency and public accessibility of these disclosures. Companies that fail to meet disclosure requirements face fines of up to $10,000, while those providing false or misleading information can face penalties up to $200,000.
New Zealand's law aligns with international frameworks while reflecting the country's unique trade and policy context.
New Zealand's proposed legislation is closely modeled on Australia's Modern Slavery Act, but with notable additions. Unlike Australia's existing framework, New Zealand's law would also require reporting on worker exploitation in domestic supply chains — not just international ones. Many New Zealand companies are already reporting on their operations and supply chains in Australia, with 238 New Zealand-headquartered companies having reported under the Australian regime. The proposed law also goes further than some comparable laws in requiring companies to disclose the number of modern slavery complaints received and the details of remediation measures taken. However, critics note that compared to laws in France, Germany, Norway, and the EU, the New Zealand legislation does not yet include mandatory due diligence obligations — meaning companies must report on risks but are not explicitly required to take action to eliminate them. The government has indicated stronger due diligence and take-action obligations may be developed at a later stage. The legislation is also intended to fulfill commitments laid out in New Zealand's free trade agreements with the EU and UK, demonstrating the country's commitment to combating modern slavery and aligning with the ethical sourcing expectations of its key trading partners.
Early preparation is essential — acting before the law is finalized will reduce compliance risk and demonstrate leadership.
Although the legislation is still progressing through New Zealand's parliamentary process, the direction is clear: companies will be held accountable for exploitation in their supply chains. Acting early will not only reduce future compliance risks, it will demonstrate leadership. Many New Zealand businesses have already started preparing voluntarily, recognizing that action is essential to maintain competitiveness, safeguard exports, and build trust with consumers and international partners. Practical steps companies can take now include confirming whether they meet the revenue threshold and have New Zealand operations in scope; mapping supply chain risk hotspots in categories that commonly carry elevated risk such as labor hire, cleaning, facilities, construction, manufacturing inputs, logistics, and high-risk geographies; and commencing internal education and training for senior management, procurement, legal, and HR teams. Experience from Australia and the UK shows that education is crucial for an organization to address modern slavery effectively. At FRDM, we specialize in empowering companies to meet regulatory obligations like New Zealand's Modern Slavery Law — and to go beyond compliance to build ethical, resilient supply chains. We have helped global banks, retailers, manufacturers, and government agencies take control of their supply chain risk, and we are ready to support New Zealand entities and their global trading partners through this transition. Ethical sourcing is no longer optional — it is enforceable, and it is the future of business.
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