By Laura Scampion and Gemma Livingston,
As New Zealand reflects on its standing in the latest Corruption Perceptions Index, attention is increasingly turning to the integrity of business practices and supply chains at home. One area under renewed scrutiny is modern slavery and worker exploitation, where gaps in oversight can enable both human rights harm and broader corruption risks.
On 10 February 2026, a bipartisan Modern Slavery Bill (the Bill) will be presented to Parliament for its first reading. Co-sponsored by National and Labour, it is expected to proceed to the Select Committee and, if enacted before the general election, the new reporting regime could take effect in early 2027, with first reporting required in 2028.
While modern slavery frameworks in Australia, the UK and the EU are diverging, New Zealand’s proposal combines transparency with penalties, incident reporting and ministerial oversight. This shifts modern slavery from a disclosure exercise to a matter of governance and accountability. Understanding what this legislation does differently, and what that means in practice, makes it essential reading, even for businesses already reporting under overseas regimes.
Why this matters for New Zealand
Modern slavery thrives where supply chains lack visibility, accountability and effective oversight. Those same conditions heighten exposure to fraud, abuse of power and organised crime. Addressing exploitation therefore strengthens both human rights outcomes and institutional integrity.
The risk is not confined offshore. An estimated 8,000 people are living in slavery-like conditions within New Zealand. The increasing exploitation of migrant workers has been identified as a key integrity risk and a contributing factor in New Zealand's declining Corruption Perceptions Index score.
The Bill does not require businesses to trace every input across global supply chains or guarantee the absence of exploitation. Instead, it promotes a proportionate, risk-based approach. Large entities would be expected to identify key risks, disclose incidents or credible concerns, implement due diligence processes, provide effective grievance mechanisms and demonstrate continuous improvement over time.
Although the regime directly applies only to larger organisations, the effects will flow through the wider economy. As reporting entities embed modern slavery expectations into procurement and contracting, suppliers will also face higher standards. Early alignment will help smaller businesses remain competitive and meet customer and investor expectations.
Key features of the Bill
Businesses operating in New Zealand with consolidated revenue of at least NZD100 million would be required to publish an annual modern slavery statement on a publicly accessible website.
Reporting is expected to cover:
• operations and supply chains
• the number of complaints received and how they were investigated and remedied
• known or anticipated risks of modern slavery
• actions taken to assess and address those risks, including due diligence and remediation processes
• how effectiveness is measured
• employee consultation and training
Requiring disclosure of complaints, investigations and outcomes expands New Zealand's reporting requirements beyond those currently found in other jurisdictions.
Oversight and enforcement
The Bill strengthens public oversight by requiring the responsible Minister to monitor compliance and report annually to Parliament on progress in combatting modern slavery, including data on referrals, investigations, prosecutions and victim support. The New Zealand Human Rights Commission would also have a formal review role, and the regime would be evaluated within three years of commencement.
Importantly, the framework includes enforceable consequences. Proposed measures include fines for non-compliance or misleading statements, liability for directors and managers, public disclosure of breaches, and exclusion from government procurement.
These settings elevate modern slavery risk so that accountability sits not only with the organisation, but with those responsible for governance, culture and resourcing. The Bill reinforces expectations of active oversight and board-level assurance.
Practical next steps for organisations
Although first reporting is likely to begin in 2028, preparation takes time. Organisations should begin by assigning clear ownership at senior management and board level; reviewing policies and contractual processes; documenting core business activities, goods and services (starting with their own workforce and tier-one suppliers); considering the most salient modern slavery risks, strengthening grievance mechanisms; and raising awareness across the business.
Early action will reduce compliance pressure and support more meaningful, credible disclosure.
Further guidance is available in DLA Piper’s detailed insights on the proposed regime.
About the authors
DLA Piper advises organisations in New Zealand and internationally on regulatory risk, governance and human rights compliance, including modern slavery reporting, investigations and supply chain due diligence.
Gemma Livingston is a Special Counsel specialising in Responsible Business at DLA Piper New Zealand. Laura Scampion is Country Managing Partner of DLA Piper New Zealand and Head of Employment.
