On 28 May 2026, Property Council submitted on the Modern Slavery Bill.
Why this matters to our members
A number of Property Council members are already undertaking modern slavery reporting through international regulatory requirements or contractual obligations, and therefore recognise the importance of New Zealand also having an effective regime to help combat modern slavery and exploitation domestically and across global supply chains.
Our view
While Property Council supports the intent of the Bill, we are concerned that aspects of the proposed regime go further than comparable international frameworks and may create uncertainty for reporting entities. Alignment with established international approaches will be important to minimise unnecessary compliance burden and support practical implementation. We also consider that the initial focus of the regime should be on education and capability-building, rather than overly punitive enforcement measures at the outset.
At high level, we recommended that:
- Clarity is provided on which Government agency will be responsible for administering and regulating the regime, including the Registrar function, to support effective implementation and consistent administration of compliance expectations;
- A risk-based and proportionate approach to be applied to reporting, with initial focus directed toward higher-risk areas of supply chains;
- The definition of “reporting period” aligns with a reporting entity’s own financial reporting period;
- The definition of “supply chain” is developed to provide greater certainty regarding the extent to which due diligence obligations are intended to apply across supplier tiers and business relationships;
- Where entities form part of a wholly owned group that prepares consolidated financial statements, only the parent company is required to prepare and submit a modern slavery statement on behalf of the group;
- The Bill allows for joint or consolidated modern slavery statements for related groups;
- The requirement to report on “anticipated risks” is removed;
- The scope and allocation of liability under Clause 16 is better clarified, to ensure responsibility is clearly defined in practice;
- The director liability provisions are removed from the Bill;
- The initial implementation period of the Act be treated as a structured education and transition phase, with enforcement measures only taking full effect after three years from commencement;
- The proposed amendment to the Public Finance Act 1989 be clarified to ensure it does not unintentionally disrupt routine Crown payments or standard government contractual arrangements, including procurement and leasing;
- The period of time between Royal Assent and commencement is extended from six months to 18 months to provide reporting entities sufficient time to implement necessary reporting systems and processes; and
- The Government take responsibility for ensuring that clear and practical guidance is issued well in advance of the first reporting obligations coming into force.
Read the full submission.