The bill will pass
The Modern Slavery Bill passed its first reading on 30 April 2026 with every party except ACT voting in favour. It now heads to the Education and Workforce select committee, but the outcome is not in doubt. National and Labour are both committed to supporting it through all stages, giving it a clear runway to Royal assent before the November 2026 election.
The bill was advanced using Standing Order 288, the ‘Rule of 61’, invoked for the first time in New Zealand parliamentary history. National’s Greg Fleming and Labour’s Camilla Belich co-championed it across party lines, bypassing ACT’s Cabinet-level block. This is no longer a question of whether. It is a question of when.
Who is in scope and what they must do
The bill applies to entities with annual consolidated revenue exceeding $100 million, covering New Zealand companies and overseas companies carrying on business here. Crown entities, local authorities, trusts, and partnerships are also bound. Greg Fleming estimated that around 300 New Zealand companies already conduct supply chain due diligence for labour exploitation, with another 700 newly affected.
Reporting entities must prepare and publish annual modern slavery statements describing how they identify, address, mitigate, and remediate modern slavery risks within their operations and supply chains. Statements go to a public Registrar within six months of the reporting period’s end. The bill comes into force six months after Royal assent, a short runway for businesses that have not started.
Gary Shaw, an expert in modern slavery and former member of the Modern Slavery Leadership Advisory Group, explained the core obligation: ‘The goal is that businesses will be required to have visibility in their supply chains and to be transparent about it.’
Director liability is the sleeper issue
The penalties are substantial. Companies that fail to report or make false statements face criminal fines up to $200,000 or civil penalties up to $600,000. But the real sting is personal.
The bill creates personal liability for directors and any ‘person involved in the management’ of a reporting entity if a breach occurs under their authority, permission, or consent. Legal analysis from Newsroom in February noted this provision ‘appears contrary to the trend of other recent reforms where personal liability provisions have been wound back.’ Boards that treat this as a compliance department problem are misreading the legislation.
Part 5 of the bill also amends the Public Finance Act 1989 to prevent Crown payments to entities convicted of offences under the act. For any business reliant on government contracts, that is a direct commercial threat, not a reputational footnote.
Smaller businesses are not exempt, just not named
Although the threshold captures just under 1,000 businesses, the supply chain cascade will reach far deeper. Reporting entities will embed modern slavery expectations into procurement and contracting. Suppliers will face higher standards regardless of their own revenue.
The exposure is not abstract. Shaw noted that 97 percent of polysilicone used in solar panels comes from forced labour. A 2019 World Vision report estimated 5 percent of New Zealand’s total imports were linked to child labour or forced labour. Any business procuring solar installations, electronics, or construction materials has supply chain risk it can no longer afford to ignore.
MBIE’s Regulatory Impact Statement from January 2024 estimated first-year compliance costs at $20 million to $60 million across entities in scope, with an average cost of around $15,000 per entity for a comprehensive statement. Those figures predate the bill’s stronger penalties and are likely conservative.
ACT’s objection is not wrong, just outvoted
ACT MP Laura McClure called modern slavery a ‘moral abomination’ but said the bill was ‘not actually good policy’. The concern is legitimate. Mandatory annual reporting, a public register, personal director liability, and Crown procurement exclusions represent a substantial new governance layer. The MBIE RIS itself acknowledged that effectiveness depends on how rigorously companies engage rather than treating it as a compliance checkbox.
Rebekah Armstrong, head of advocacy at World Vision, made the same point from the other direction: without genuine incentive to perform real checks, the $100 million threshold risks becoming a tick-box exercise.
What boards should do now
The select committee process will take months, but the bill’s architecture is set. Businesses over $100 million should be assigning governance ownership for modern slavery risk, mapping their supply chains, and preparing reporting frameworks. Those already reporting under Australian or UK regimes have a head start. Those that are not have perhaps 12 months before the first statements are due.
For the thousands of smaller businesses that supply them, the message is simpler: your largest customers are about to ask questions you have never been asked before. Having answers ready is now a competitive advantage.
Sources
- Modern Slavery bill passes first reading under new Parliament rule (2026-04-30)
- The Detail: Modern slavery bill a triumph of parliamentary co-operation (2026-04-30)
- Labour, National reach across aisle to tackle modern slavery (2026-01-29)
- Large New Zealand entities to face new laws on modern slavery (2026-02-03)
- There’s finally a bipartisan modern-day slavery bill. How will it work? (2026-02-02)
- Regulatory Impact Statement: Modern Slavery and Worker Exploitation Reform (2024-01-15)
- Watch: National and Labour MPs team up to get slavery bill heard after ACT objects (2026-01-29)