Modern slavery reporting: New Zealand moves closer to Australian model

New Zealand’s Modern Slavery Bill has been reported back to Parliament, with the Education and Workforce Committee recommending that the majority of it be passed. The proposed regime now more closely reflects Australia’s established reporting framework, while retaining stronger enforcement consequences.

If passed, the Bill will require larger entities to report annually on modern slavery risks and due diligence across their operations and supply chains. Although the timing remains uncertain, businesses operating across Australia and New Zealand should prepare for increasingly aligned expectations.

Key New Zealand changes

• Threshold: An entity must meet or exceed NZ$100 million in revenue in each of its two preceding accounting periods.
• Timing: Statements will generally be due within six months after balance date. Transitional provisions provide a longer lead-in before the first statements are due.
• Group reporting: A parent entity may submit a single statement covering the relevant itself and any subsidiaries that meet the revenue threshold.
• Australian statements recognised: An entity reporting under Australia’s Modern Slavery Act 2018 may use that statement for New Zealand purposes, reducing duplication for trans-Tasman businesses.
• Central publication: Statements will be published on a public register, with no separate requirement to publish them on the entity’s own website.

Why this matters for businesses

The practical impact will extend beyond entities that meet the statutory threshold. Larger businesses are likely to pass information, assurance and audit requirements down through procurement processes, franchise systems and supplier contracts.

In labour-intensive sectors such as commercial cleaning, modern slavery controls may also affect tender evaluation. Tenderers that price below a sustainable level may face closer scrutiny about whether wages, employment obligations and subcontracting risks can realistically be managed. The regime will not regulate pricing directly, but it may support more informed assessment of unusually low bids and the labour practices underlying them.

How businesses can prepare

• Map the supply chain: Identify higher-risk suppliers, labour models, products and jurisdictions.
• Align trans-Tasman reporting: Develop one reporting process that can support obligations in both countries.
• Review contracts and franchise documents: Include proportionate information, audit, training, remediation and termination rights.
• Review tender processes: Consider whether procurement criteria adequately test labour costs, subcontracting practices and the credibility of unusually low pricing.
• Set accountability: Ensure directors and senior managers have appropriate oversight of reporting and risk management.

Modern slavery reporting is becoming more coordinated and more closely linked to meaningful risk management. Preparing early should reduce duplication and make it easier to respond to both customer and regulator expectations. The Wynn Williams team will be keeping a close eye on this area of law, and is happy to discuss what the proposed reporting obligations may mean for your business.

Katrina Hammon, Partner – Wynn Williams General Business & SMEs team

Melissa Parmar, Associate, – Wynn Williams General Business & SMEs team