Transparency International New Zealand has made a submission to Parliament on the Modern Slavery Bill 2026, broadly welcoming the legislation while urging significant strengthening before it becomes law.
Modern slavery isn't a distant problem. The Walk Free Foundation estimates around 8,000 people are living in conditions of modern slavery in New Zealand right now. Globally, the International Labour Organisation puts the figure at 50 million on any given day — and that number is rising. Closer to home, World Vision research suggests the average New Zealand household spends $77 per week on goods likely produced through child or forced labour, amounting to nearly $8 billion annually.
Against this backdrop, the Modern Slavery Bill 2026 — a cross-party initiative championed by Labour MP Camilla Belich and National MP Greg Fleming — represents a long-overdue step. TINZ has submitted to the Education and Workforce Committee in support of the Bill's core intent, while identifying several areas where the legislation could be made more effective.
What the Bill Does
The Bill would require large organisations with consolidated revenue exceeding $100 million to publicly report on modern slavery risks in their operations and supply chains. A public register of statements would be created, and non-compliant entities would face civil and criminal penalties, as well as a ban from government procurement. TINZ welcomes these foundations — mandatory public reporting, a searchable register, and meaningful penalties are all best-practice elements for transparency and accountability.
Where It Falls Short
The most significant concern is that the Bill requires organisations to report on their due diligence efforts — but doesn't actually require them to undertake due diligence. This risks reducing compliance to a box-ticking exercise rather than driving real change. The UK's House of Lords and Australia's statutory review of their equivalent legislation have both concluded that reporting-only models are insufficient and recommend mandatory due diligence. New Zealand does not need to repeat that mistake by designing in the same weakness from the outset.
Improved definitional clarity is needed in the bill — key terms like "carried on business in New Zealand," "operations," and "supply chains" are left undefined, creating uncertainty for businesses trying to comply and potential inconsistency in enforcement.
The $100 million revenue threshold is another sticking point. While mirroring Australia's approach, this threshold excludes the small and medium businesses most concentrated in high-risk sectors like garments, agriculture, hospitality, construction, and cleaning services. TINZ supports the ability to lower this threshold by regulation, but wants clearer criteria — including a requirement to consider the Bill's overall effectiveness — to guide that decision.
Practical Fixes on the Table
Our submission also proposes several practical improvements: allowing organisations to align their reporting period to their own financial year (rather than a fixed April–March cycle); permitting joint group statements for related entities; and expressly enabling voluntary reporting by NGOs and smaller businesses that fall below the threshold.
On enforcement, it is important that penalties be proportionate and focused on encouraging transparency and improvement — not driving concealment. Early-stage enforcement should centre on education and support rather than punitive action.
Looking Ahead
New Zealand is entering a global regulatory environment where the European Union has moved to mandatory due diligence. Both Australia and the UK have officially recognised the need to strengthen their own legislation. If New Zealand's law is to remain relevant, TINZ argues that its review provisions — currently set at three to five year cycles — must be robust enough to track those international developments and consider upgrading to a due diligence model.
The Bill is a genuine step forward. With the amendments TINZ recommends, it could be a meaningful one.
