Modern slavery reporting in NZ – practical steps to enable compliance and drive action

Mathieu Hemery
May 2026
Mosaic

While climate disclosure momentum has slowed, New Zealand is making meaningful progress in another critical area: modern slavery, with an aim to pass into law before the elections in November this year. There was tremendous mahi by relentless advocates such as World Vision New Zealand to reach the stage this legislation is at.

Scope and Requirements

Similarly to climate disclosures, this will be a disclosure-based regime, with no mandated action – so entities will be required to make the disclosure but are not required to take any action from it. 

However, transparency itself can drive change, especially when supported by robust standards and independent assurance. 

Reporting entities are those with a revenue of more than NZD 100m. The modern slavery statement will need to cover:

  • Organisational structure, operations and supply chains
  • Identified incidents and current and anticipated risks
  • Governance and risk management processes
  • Complaints handling and remediation
  • Training to support identification and response 

Compliance and Risk Exposure

The bill also describes the details on the expectations for the report publication and truthfulness. 

Furthermore, there are other structural features which have been confirmed, such as a public register of modern slavery statements, a Registrar role to operate the register, as well as ministerial reporting to Parliament on the progress, and formal involvement of the Human Rights Commission.1

Compared to Australia, New Zealand’s proposed regime goes further. Australia focuses on risk management and remediation, but does not explicitly require disclosure of incidents or complaints, or how they are handled. It also lacks penalties for misleading statements.
New Zealand’s approach is more prescriptive and introduces real enforcement risk. 

Systems and Data Readiness

For organisations, this is not just a reporting exercise. It requires:

  • Deeper supply chain engagement
  • Reliable data collection and governance
  • Clear audit trails for decisions and actions
  • Mechanisms to safely capture worker voice

Technology has a role to play to support organisations, for example through anonymous worker insights collection for suppliers, and providing insights with analytics to the entity interested by the survey.

Equally important is the ability to track complaints through to resolution, document responses, and substantiate disclosures. 

Yes, this can start in spreadsheets - but it shouldn’t stay there.The role of sustainability teams is to drive real-world outcomes. Organisations should prepare for the emerging reporting requirements by understanding the needs and investing appropriately in solutions, before the reporting requirements are in place (expected to be in 2028).

1. https://www.legislation.govt.nz/bill/members/2026/242/en/latest/#LMS1569557

Modern slavery reporting in NZ – practical steps to enable compliance and drive action

Published
May 2026
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While climate disclosure momentum has slowed, New Zealand is making meaningful progress in another critical area: modern slavery, with an aim to pass into law before the elections in November this year. There was tremendous mahi by relentless advocates such as World Vision New Zealand to reach the stage this legislation is at.

Scope and Requirements

Similarly to climate disclosures, this will be a disclosure-based regime, with no mandated action – so entities will be required to make the disclosure but are not required to take any action from it. 

However, transparency itself can drive change, especially when supported by robust standards and independent assurance. 

Reporting entities are those with a revenue of more than NZD 100m. The modern slavery statement will need to cover:

  • Organisational structure, operations and supply chains
  • Identified incidents and current and anticipated risks
  • Governance and risk management processes
  • Complaints handling and remediation
  • Training to support identification and response 

Compliance and Risk Exposure

The bill also describes the details on the expectations for the report publication and truthfulness. 

Furthermore, there are other structural features which have been confirmed, such as a public register of modern slavery statements, a Registrar role to operate the register, as well as ministerial reporting to Parliament on the progress, and formal involvement of the Human Rights Commission.1

Compared to Australia, New Zealand’s proposed regime goes further. Australia focuses on risk management and remediation, but does not explicitly require disclosure of incidents or complaints, or how they are handled. It also lacks penalties for misleading statements.
New Zealand’s approach is more prescriptive and introduces real enforcement risk. 

Systems and Data Readiness

For organisations, this is not just a reporting exercise. It requires:

  • Deeper supply chain engagement
  • Reliable data collection and governance
  • Clear audit trails for decisions and actions
  • Mechanisms to safely capture worker voice

Technology has a role to play to support organisations, for example through anonymous worker insights collection for suppliers, and providing insights with analytics to the entity interested by the survey.

Equally important is the ability to track complaints through to resolution, document responses, and substantiate disclosures. 

Yes, this can start in spreadsheets - but it shouldn’t stay there.The role of sustainability teams is to drive real-world outcomes. Organisations should prepare for the emerging reporting requirements by understanding the needs and investing appropriately in solutions, before the reporting requirements are in place (expected to be in 2028).

1. https://www.legislation.govt.nz/bill/members/2026/242/en/latest/#LMS1569557

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