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

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