The Modern Slavery Bill ("Bill") passed its first reading this week and has been referred to the select committee, after Labour secured concessions to prioritise the Bill during discussions on the NZ–India FTA. With support across all political parties except the ACT Party, the Bill is intended to be passed before Parliament rises for the election on 24 September. Public submissions close on 28 May 2026, with the select committee due to report back by 31 August.
During the first reading debate, the Bill’s co‑sponsor, Camilla Belich MP, acknowledged that, as a members’ bill developed without formal ministry support, the Bill would benefit from close scrutiny at the select committee stage. She encouraged those affected (such as businesses that will be required to report) to engage through submissions to help ensure the framework is practical and effective.
Our previous insight summarises the Bill, including its scope and the reporting requirements that would apply to businesses. This insight highlights a number of key issues that submitters may wish to consider:
- overseas companies carrying on business in New Zealand: whether the Bill’s reference to an “overseas company that carries on business in New Zealand” is sufficiently clear and aligns with existing concepts under the Companies Act 1993;
- interaction with overseas reporting regimes: how the New Zealand reporting regime is intended to interact with modern slavery statements prepared under other jurisdictions’ regimes (such as Australia), noting that the Bill imposes additional reporting requirements not presently mirrored in Australian legislation (including incident, complaints, continuous improvement and employee training reporting), and that while similar reporting requirements were recommended in Australia in 2023 and consulted on in 2025, they have yet to be implemented;
- group and joint reporting: whether, and on what basis, related entities should be permitted to prepare a single joint or group modern slavery statement, particularly for corporate groups with centralised governance and reporting, noting that Australian legislation expressly permits joint modern slavery statements covering one or more reporting entities, subject to specified consultation, approval and signing requirements;
- reporting periods: whether fixing a reporting period ending 31 March (rather than aligning with an entity’s financial year) creates practical or operational challenges for businesses;
- definition and scope of supply chains: how far down the supply chain reporting is expected to extend (for example, whether it is limited to tier 1 suppliers or extends beyond tier 2), whether customers are included or excluded, and how commercially sensitive or confidential information should be treated;
- incident reporting without a due diligence duty: the practical implications of requiring entities to report modern slavery “incidents” in the absence of a positive obligation to identify or prevent them, including what this means for internal processes and investigative expectations; and
- liability and penalties: whether the proposed liability and penalty framework strikes an appropriate balance between incentivising meaningful culture change and avoiding outcomes that are unduly punitive for reporting entities.
If you would like assistance in preparing a submission on the Bill, or would like to discuss how the Bill may apply to your organisation, please get in touch with one of our experts.