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28 July 2026

Modern Slavery Reporting: A Comparative Guide To The UK, Australia, California, And New Zealand Frameworks

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A&O Shearman

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New Zealand's Modern Slavery Bill marks a significant development in global anti-slavery legislation, joining jurisdictions like the UK, Australia, and California in requiring large companies to report on slavery and human trafficking risks. How does this new framework compare to existing international standards, and what implications will it have for businesses operating across multiple jurisdictions?
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New Zealand’s Modern Slavery Bill (the NZ Bill) represents the latest iteration of modern slavery reporting legislation around the world. Introduced in the New Zealand Parliament on February 10, 2026, the NZ Bill passed its first reading in the House of Representatives on April 29, 2026. 

It has since been referred to the Education and Workforce Select Committee (the Select Committee) and will revert to the House on August 31, 2026. If passed, the NZ Bill would come into effect six months after receiving royal assent.

The NZ Bill follows a broader global legislative trend of requiring certain large companies to publish annual slavery and human trafficking statements, beginning more than a decade ago with the California Transparency in Supply Chains Act (the California Act), which came into effect on January 1, 2012.

The UK later enacted the Modern Slavery Act 2015 (the UK MSA), whose reporting provisions entered into force on October 29, 2015. Australia soon followed with the Australian Modern Slavery Act 2018 (Cth) (the Australian MSA), which became effective on January 1, 2019.

In this bulletin, we unpack the modern slavery reporting frameworks in the UK, Australia, California, and New Zealand, with a particular focus on the NZ Bill and how it would interact with the existing regulatory landscape.

For our full comparative analysis, download the PDF below.

Modern slavery reporting

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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