Modern slavery reporting in Australia and New Zealand

By the Generate Zero Team  |  Published October 2026  |  Modern Slavery

Modern slavery reporting is changing in Australia and New Zealand

If a customer asked how you assess modern slavery risk in your supply chain, what could you show them? A policy is a starting point. Supplier assessments, follow-up questions and records of action tell them much more.

Proposals in Australia and New Zealand make that question more pressing. New Zealand’s Modern Slavery Bill would introduce reporting obligations for larger entities. Australia is proposing a criminal offence for failing to prevent modern slavery in supply chains. Both remain proposals.

New Zealand: the Modern Slavery Bill

The Education and Workforce Committee recommended that the Modern Slavery Bill be passed with amendments. For businesses, the main proposals are:

• Who's in scope: entities with consolidated revenue above $100 million in each of their two preceding accounting periods. Around 1,250 New Zealand entities are estimated to meet that threshold (Chapman Tripp).

• What statements must cover: modern slavery risks in the entity's operations and supply chains, and the due diligence actions taken during the reporting period.

• Timing: the proposed Act would commence six months after enactment, with reporting deadlines following the first full reporting period. The exact first deadline would depend on the entity’s balance date and the final legislation.

• Group and trans-Tasman reporting: a parent can report for its group, and entities already reporting under Australia's Modern Slavery Act 2018 can submit their Australian statement to meet New Zealand's requirements.

• Enforcement: the Registrar can require information, request remedial action and publish details of persistent non-compliance. Offences apply to knowingly false or misleading statements.

The Bill did not complete its final readings before the election. It can be reinstated in the next Parliament, but its timing and final form remain uncertain. Organisations can use this time to work out what supplier information they hold and where their due diligence records need attention.

Australia: a proposed failure-to-prevent offence

Australia already requires eligible entities to publish modern slavery statements. The proposed reforms would add stronger enforcement and a separate criminal offence.

In July 2026, the Australian Government announced plans for a failure-to-prevent offence covering corporations with annual consolidated revenue over AUD 100 million. The proposal includes a defence where reasonable steps have been taken to prevent modern slavery in the supply chain. The Government also intends to introduce civil penalties for non-compliance with existing reporting obligations. Consultation on the proposed offence was announced on 21 August 2026; the details remain subject to reform.

While the details are still being developed, organisations can prepare by:

• identifying where modern slavery risk sits in their supply chains

• assessing and prioritising suppliers based on that risk

• taking proportionate action to manage the highest risks

• keeping records that show those steps over time.

Why this matters for New Zealand organisations

A New Zealand business may also face questions from its Australian customers. If those customers need to demonstrate how they manage supply chain risk, they may ask suppliers for information about sourcing, assessments and follow-up action.

Being able to retrieve that information matters. A statement is easier to substantiate when the team can show which suppliers it assessed, why it prioritised them and what happened next.

Where to start

Start with your supplier records and purchasing data. They show who you pay and what you buy. They may also reveal gaps: missing supplier locations, broad spending categories or assessments that haven’t been revisited.

1. Map your spend. Use supplier and general ledger data to understand what you buy, from whom and from which sectors and countries.

2. Look beyond Tier 1. A direct supplier’s own risk profile may not capture exposure further upstream. [LINK: Article 5]

3. Prioritise. Focus due diligence on the suppliers and categories where risk is highest, rather than trying to investigate everyone equally.

4. Keep records as you go. Save the assessment, the reason for any follow-up and the action taken. Record outcomes when you know them.

5. Revisit assessments. New enforcement information or adverse media can change what you know about a supplier. Decide how the team will pick up those changes between reporting cycles.

How Generate Zero can help

Generate Zero’s Modern Slavery Risk Intelligence uses supplier and general ledger data to help you identify where to focus due diligence. It combines local and global sources with country, sector, commodity and company information to assess risk and show the evidence behind that assessment.

It sits alongside emissions reporting in Generate Zero, helping teams use their existing supplier data across both areas.

If you’d like to see what this could reveal about your suppliers, get in touch.