Two directors already face personal liability under a law not yet passed

Delayed is not dead

A group of New Zealand charities has urged Prime Minister Christopher Luxon to push the Modern Slavery Reporting Bill through Parliament before the 7 November election. Labour MP Camilla Belich, who co-authored the bill with National MP Greg Fleming, wanted a cross-party agreement to get it over the line. Luxon has ruled that out, but has pledged to bring the law back next term.

That pledge is the whole story for businesses. The bill is not dead, it is delayed, and the distinction matters far less than the affected companies might hope. The Education and Workforce Select Committee recommended the bill be passed into law on 1 September 2026. It has cross-party support from National, Labour and the Greens. Treating this as a distant hypothetical is a mistake.

What the law actually asks for

The core obligation is straightforward. Entities with annual revenue above $100 million must publish annual statements covering their structure, operations, supply chains, imported goods and their origin, risk assessments, prevention measures and remediation procedures. More than 1,000 companies and government departments sit above that threshold, though phasing means some may not produce their first statements until 2029.

The penalties are the part boards need to read twice. Civil penalties of up to $600,000 apply for non-compliance, directors and senior managers could face personal liability for material breaches, and knowingly making a materially false statement carries a fine of up to $200,000. Personal exposure changes the calculus. This is not a filing obligation you can safely delegate and forget.

Why the direction is locked in

Even if the bill lapses this term, the trajectory is set. The bill was introduced under Standing Order 288, the first use of a mechanism that lets a member’s bill bypass the ballot. ACT is the only party opposing it, arguing compliance costs have not been shown to improve outcomes for victims, a legitimate point about design rather than direction.

More importantly, New Zealand’s trading partners already operate under equivalent or stricter regimes. Australia has had legislation since 2019, the UK has its Modern Slavery Act, and the EU’s Corporate Sustainability Due Diligence Directive imposes mandatory, not merely encouraged, due diligence on large firms exporting into Europe. New Zealand is joining a cohort that includes its most important markets. Exporters selling into the EU will face those requirements regardless of what Wellington does.

The scale most buyers underestimate

World Vision estimates New Zealand households spend about $77 a week on goods at risk of forced or child labour, close to $8 billion a year, and around 8,000 people are living in some form of modern slavery here. The exposure is not theoretical. Woolworths’ 2026 statement flagged a potential case in its extended supply chain, and since 2020 the retailer has overseen repayment of more than $2.3 million to workers in its supply chain.

The governance case for moving now

Matt Prichard, Chair of KPMG New Zealand and World Vision New Zealand, made the argument plainly in August 2026, writing for the Institute of Directors. “Complex global supply chains cannot be made risk-free overnight,” he wrote. “The question is whether organisations are willing to search for harm even when finding it may be inconvenient, embarrassing or costly.” Done properly, he argued, disclosure “requires organisations to map risk, confront uncomfortable truths, build grievance channels, investigate complaints, remediate harm and test whether their response is working.”

Where the legitimate fight is

Business has a real interest in how this regime is built, not whether it exists. BusinessNZ’s May 2026 submission supported the intent but warned against duplication, arguing that “where equivalent reporting is already being undertaken in other recognised jurisdictions, New Zealand should seek to leverage that reporting rather than require parallel compliance processes.” It also pushed for a tiered approach and phased implementation. Foodstuffs went further, arguing the law should be handed back to MBIE for more policy work.

On the other side, academics Dr Brent Burmester and Professor Christina Stringer argued for mandatory due diligence and a lower $50 million threshold that would still capture only 0.4 percent of firms. The support base has been consistent for years. Back in 2022, MBIE’s consultation drew 5,614 submissions with 95% backing action by all entities, yet no law passed before the 2023 election.

The smart move for large buyers and exporters is to stop waiting. Map the supply chain, build the grievance and remediation machinery, and lobby now for mutual recognition of overseas reports so the eventual regime is workable. The law is coming back. The only real question is whether boards use the delay to prepare or to procrastinate.

Sources

• Charities push to get modern slavery law through dying days of Parliament (2026-09-21)
• Select committee recommends Modern Slavery Bill be passed into law (2026-09-01)
• Modern slavery reporting laws are coming. Will they make a difference? (2026-09-11)
• NZ is finally moving on modern slavery law. What can we learn from Australia? (2026-09-09)
• Modern slavery law risks ‘significant cost burden’, companies argue (2026-06-16)
• Modern Slavery Bill: New Zealand’s moment to ‘look behind the label’ (2026-08-14)
• BusinessNZ Submission on Modern Slavery Bill (2026-05-11)