• Develop and implement formal SOPs for victim identification and train all front-line officials on them, including law enforcement, customs officials, and labor inspectors.
• Increase efforts to identify victims through proactive screening of vulnerable populations, including New Zealand citizens, foreign workers, children, and individuals in the decriminalized commercial sex industry.
• Increase efforts to proactively investigate and prosecute sex and labor trafficking crimes, and seek adequate penalties for convicted traffickers, which should involve significant prison terms.
• Establish a formal referral mechanism to refer all victims to appropriate care, even if they choose to not participate in criminal proceedings or a criminal case does not move to prosecution, and train officials on its use.
• Increase coordination with NGOs, social service providers, and other civil society stakeholders on anti-trafficking efforts, including victim identification and assistance; provide support to NGOs for trafficking victim services provisions, including shelter.
• Update the National Action Plan (NAP), in collaboration with civil society and other anti-trafficking stakeholders, to include trafficking within New Zealand and exploitation of New Zealand nationals.
• Amend the trafficking statute to explicitly define the sex trafficking of children as not requiring the use of deception or coercion.
• Take steps to improve potential victims’ access to services, including emergency and long-term shelter, and ensure that the process of victim certification is done in a timely manner.
• Increase training for all front-line workers, including customs officials, health care workers, and immigration officials, on trafficking indicators and appropriate referrals for victims.
• Improve interagency coordination and case response during trafficking investigations and prosecutions and victim identification, and implement a trafficking data management system.
• Provide anti-trafficking training to diplomatic personnel.

The government increased anti-trafficking law enforcement efforts; however, the government did not convict any traffickers.

The Crimes Act of 1961, as amended in 2015, criminalized sex trafficking and labor trafficking. Section 98D (trafficking in persons) criminalized all forms of labor trafficking and some forms of sex trafficking and prescribed penalties of up to 20 years’ imprisonment, a fine not exceeding 500,000 New Zealand dollars (NZD) ($280,741), or both; these penalties were sufficiently stringent and, with respect to the forms of sex trafficking covered under the provision, commensurate with the penalties prescribed for other grave crimes, such as rape. Inconsistent with the international law definition, Section 98D required a demonstration of deception or coercion to constitute a child sex trafficking offense, and therefore did not criminalize all forms of child sex trafficking. However, Section 98AA criminalized all forms of child sex trafficking under its “dealing in persons” provision and prescribed penalties of up 14 years’ imprisonment, which were sufficiently stringent and commensurate with the penalties prescribed for other grave crimes, such as rape. The government sometimes utilized the Prostitution Reform Act (PRA) to prosecute child sex trafficking crimes, including Sections 20 and 21, which criminalized facilitating, assisting, causing, or encouraging a child to provide commercial sex, in addition to receiving earnings from commercial sex acts provided by a child. These sections of the PRA prescribed penalties of up to seven years’ imprisonment, which were significantly lower than those available for trafficking offenses under Section 98D and 98AA of the Crimes Act. Legislation that would align the penalties prescribed for slavery-related offenses, including Section 98AA, with the penalties prescribed under Section 98D was pending approval from Parliament at the end of the reporting period.

In 2024, a systemwide update to improve the government’s data collection processes related to human trafficking limited the scope of year-to-year comparison for assessment purposes. As a result, 2024 data may include duplicate cases from the previous reporting period. During the reporting period, the government made efforts to centralize its data system. The government did not disaggregate law enforcement information by type of trafficking. The government reported initiating 53 new investigations in 2024, compared with initiating six trafficking investigations from April 2023 to March 2024; however, this figure may include non-trafficking crimes. The government reported continuing 47 investigations initiated in previous reporting periods. The government initiated four prosecutions in 2024 (two for sex trafficking and two for forced labor), compared with one prosecution for sex trafficking initiated between April 2023 and March 2024. The government also continued three prosecutions initiated in previous years. The government did not convict any traffickers in 2024, compared with convicting one sex trafficker from April 2023 to March 2024. The government has previously closed cases, without initiating prosecution, that involved allegations that included indicators of forced labor among foreign national children.

Following the enactment of the trafficking law in 2015, the government has exclusively used Section 98D to prosecute labor trafficking crimes and has never reported prosecuting a sex trafficking crime or a case of internal trafficking under Section 98D. According to the government and civil society, officials often investigated and charged trafficking crimes under different laws due to gaps in gathering evidence; as a result, some traffickers likely received lesser penalties than those available under the trafficking law. The government reported officials struggled to identify trafficking in cases involving exploited migrant workers who entered New Zealand legally. In 2024, the government reported it cooperated with foreign counterparts in six investigations and an INTERPOL operation, all of which focused on multiple crimes, including trafficking. The government did not report any investigations, prosecutions, or convictions of government officials complicit in trafficking crimes.

An anti-trafficking operations group, composed of immigration authorities, police, the children’s ministry (Oranga Tamariki), and other agencies, continued to meet monthly to increase law enforcement coordination. NZP was the lead for investigating domestic trafficking cases. The Labor Inspectorate (LI) investigated forced labor complaints but worked mainly within the civil legal system, which potentially contributed to the lack of criminal prosecution of forced labor crimes as authorities did not refer cases for criminal investigations. Immigration New Zealand’s (INZ) Immigration Compliance and Investigations Unit investigated trafficking cases that involved immigration violations; however, according to some observers, INZ was reluctant to pursue trafficking charges and the agency did not consistently coordinate with prosecutors before deciding to pursue charges. Despite finalizing a strategy in early 2021 to formalize their collaboration, some observers noted the agencies did not effectively coordinate to investigate potential trafficking cases. A government pilot investigations program initiated in the previous reported period concluded. The government did not report any recommendations or outcomes from the program, but civil society noted the initiative contributed to some progress in victim identification. In 2024, the government established an interagency task force to improve information sharing and strengthen cooperation between law enforcement, customs, and immigration officials, including in human trafficking cases. The International Child Protection Unit supported all investigations involving child victims. Some experts previously noted a lack of efforts by law enforcement to treat sex trafficking cases appropriately, which minimized recognition of the prevalence of the crime and resulted in weak efforts to hold traffickers accountable and protect victims. The government provided online and in-person anti-trafficking training to NZP and Ministry of Business, Innovation, and Employment (MBIE) officials (including labor, customs, child protection, and immigration agencies), including on trafficking indicators; however, it did not report providing training to other officials, such as judiciary officials.

The government identified more victims but maintained overall inadequate victim protection efforts.

The government reported that NZP identified 26 trafficking victims and MBIE identified 17 trafficking victims in 2024; however, some victims may have been included in both data sets. This compared with officials identifying 16 total trafficking victims between April 2023 and March 2024. Despite evidence traffickers have forced adults, particularly victims of family violence who are women, into commercial sex in New Zealand, the government has never reported identifying an adult New Zealand citizen as a sex trafficking victim.

The government reported finalizing victim identification SOPs for MBIE officials, including immigration officials; however, the government did not consistently implement these SOPs as they were pending approval at the end of the reporting period. The government did not develop such guidelines for all frontline officials across all enforcement agencies. A civil society group reported immigration and customs officials did not consistently screen for trafficking indicators, including forced criminality, at ports of entry into the country. The government lacked a system to formally recognize all trafficking victims, including child victims and victims with New Zealand citizenship, and to track subsequent data. This impeded the government’s ability to identify trafficking trends and develop and implement effective responses; according to civil society, this also limited the government’s understanding of the extent of trafficking in New Zealand. Some government officials misunderstood trafficking to require cross-border movement and only involving foreign nationals, contributing to a lack of identification of victims from New Zealand. Civil society and the media previously reported migrants who engaged in commercial sex in New Zealand – which was only decriminalized for adult New Zealand nationals – were highly vulnerable to exploitation. Due to regulations limiting police from inspecting legal brothels without a complaint or suspicion of an offence having been committed, police deferred to Ministry of Health (MOH) officials and an organization working closely with individuals in commercial sex to report potential criminal violations; however, the government did not provide training to the organization’s or MOH’s staff on definitions or indicators of sex trafficking, or procedures for the referral of trafficking victims to services. Due to the lack of formal identification procedures and screening of vulnerable populations, including foreign nationals in commercial sex, the government did not take effective measures to prevent the inappropriate penalization of potential victims solely for unlawful acts committed as a direct result of being trafficked.

NZP was responsible for certifying victims; MBIE submitted requests to certify victims involving transnational cases of trafficking and NZP investigators submitted requests to certify victims in domestic cases. NZP provided victim certifications to 14 foreign trafficking victims in 2024, including one child (five female victims and nine male victims). In the reporting period from April 2023 to March 2024, the government reported certifying 16 trafficking victims, noting this data may include duplicate cases from January 2024 to March 2024. The number of certified victims included victims identified in 2024 and previous years. Oranga Tamariki was responsible for conducting a certification statement for child victims in consultation with a police officer; child victims were not required to speak with law enforcement. While the government did not require New Zealand victims to be certified to access general victims of crime support services, a lack of certification prevented foreign trafficking victims from obtaining access to social service benefits, healthcare, and visa options available for victims of trafficking. Victim certification processes and the availability of subsequent service provision, including visas, remained unclear to potential victims and victim service providers, preventing some victims from accessing appropriate care and resources. The government did not make publicly available any appeals process for rejected applications. Certified victims could access free legal assistance from Community Law, but the government did not report whether any certified victims used these legal services.

In collaboration with an NGO, the government reported initiating the development of an informal referral mechanism to connect certified trafficking victims with casework and short-term counseling support provided by civil society. NGOs noted significant time gaps between a victim’s initial identification and their certification, leaving some victims without access to protection services, such as healthcare and shelter, while they waited for certification. The government reported certified victims in 2024 received services provided by civil society including medical care, resettlement assistance, livelihood support, food, and financial assistance. The government did not allocate funding specifically to assist trafficking victims and observers reported a lack of sufficient funding for victim care. New Zealand did not have any shelters, governmental or NGO, specifically designated for trafficking victims. The government referred some victims to NGOs that could assist victims of crime, including trafficking. An NGO reported the government referred six victims to their services, including three children; however, this was limited to social support and basic casework. New Zealand did not have shelter options for child victims – Oranga Tamariki placed child victims with close relatives or care providers after ensuring safety and consulting with the family or seeking a court order. Oranga Tamariki did not provide training for its social workers on trauma-informed responses for child trafficking victims. The government also lacked a framework for providing trafficking-specific services to domestic victims of trafficking. Certified trafficking victims were eligible to receive government-funded services available for all serious crime victims provided through the Ministry for Social Development, Victim Support, and arrangements with local community groups. However, an observer reported that a significant number of certified victims were not able to access protection services to which they were entitled. Observers previously reported the government lacked adequate services for child sex trafficking victims, did not provide easily accessible services for victims of both labor and sex trafficking, and did not provide clear guidance to some NGO service providers seeking government assistance.

The government allowed for a reflection period for victims, the length of which depended on the individual recovery needs of each victim, before deciding whether to cooperate with law enforcement; but the government did not report whether any potential or certified victims utilized this process. A victim advisor was available in courts to provide assistance and information to victims throughout the judicial process; however, the government did not report providing this service to any victims during the reporting period. Victims could provide testimony in writing or via video; however, the government did not report this occurring. Courts could order repatriations for trafficking victims, but the government did not report repatriating any victims. The government could fund travel and accommodation expenses for repatriated victims willing to return to New Zealand to participate in court proceedings, but it did not report funding such expenses during the year. The law authorized the extension of temporary residence visas to certified foreign trafficking victims for up to 12 months, which also made them eligible for legal employment; foreign victims facing hardship or retribution in their home countries could apply for a residency visa. INZ granted 14 victims with trafficking in persons visas, compared with 10 during the prior reporting period; INZ did not report granting any visas to trafficking victims’ family members. INZ continued to include information on visas for trafficking victims and brochures in 10 languages on its website; however, the website included a definition of trafficking that required the movement of a person, which is inconsistent with the international law definition. The law allowed victims to receive restitution from criminal proceedings and victims could seek compensation from assets forfeited in criminal cases through civil claims; however, no cases were reported this year.

The government maintained mixed efforts to prevent trafficking.

INZ chaired the government’s interagency working group on trafficking and operated a team responsible for coordinating government anti-trafficking efforts, which continued to meet monthly. The government reported it continued to implement its 2020-2025 NAP; however, an observer reported a lack of progress in implementation. During the reporting period, the government disbanded an advisory group formed in 2021 to aid in the development of a stand-alone anti-trafficking law. The government reported participating in and hosting awareness raising events on human trafficking, including with private sector and civil society participation. The government did not undertake any specific efforts to raise awareness of sex trafficking. The government continued to maintain immigration and employment websites and distribute printed and online materials to raise awareness of trafficking indicators and the availability of support services to migrant and domestic workers. Civil society previously reported low levels of public understanding of trafficking across the country. The government’s anti-trafficking efforts continued to focus primarily on the immigration system and transnational elements, which potentially led to officials overlooking sex and labor trafficking of New Zealand nationals within the country. Civil society reporting the adoption pathway continued to be used to facilitate child trafficking during the reporting period, additionally noting gaps in the law that do not require screening of potential adoptive parents. The government acknowledged its international adoption laws and pathways lacked adequate safeguarding measures, as did entertainment visas, potentially leaving children and entertainment visa holders vulnerable to trafficking; no efforts were made to address vulnerabilities during the reporting period. The government’s data collection system did not categorize child trafficking as a specific type of harm for children, which may have prevented the government from understanding the full scope of the issue, thereby hindering efforts to identify and protect child trafficking victims. The government reported conducting research to enhance its knowledge on human trafficking.

Government regulations banned employers who breached employment standards from recruiting migrant workers for periods of six to 24 months and the government published a “stand-down” list of all offending employers on its website. As a result of legal amendments made during the previous reporting period, the stand-down list was expanded to include migrant worker exploitation infringements. The Worker Protection Act requires employers to submit employee documentation within 10 days of receiving an official government request. A member of Parliament, in consultation with civil society, drafted legislation that would require companies with revenues exceeding 50 million NZD ($28.07 million) to disclose worker vulnerabilities in their supply chains, address gaps in victim services provisions and processes, and amend the law to support successful prosecution of child trafficking cases. Civil society largely supported the draft bill’s multifaceted approach to strengthen the government’s antitrafficking efforts in New Zealand but acknowledged it did not explicitly mandate due diligence measures to require companies to take action on exploitation in supply chains. The government distributed awareness material in migrant communities to inform individuals of their rights and the visa process; however, some workers remained unaware of their rights and how to report exploitation. MBIE continued to distribute pamphlets, in five languages, which listed who was legally permitted to engage in commercial sex and provided information on how to report exploitation; however, these materials did not specifically address trafficking. MBIE funded training modules developed by civil society on forced labor indicators and responsible recruitment practices for employers.

The government did not operate a trafficking specific hotline; however, the government operated emergency and non-emergency hotlines and websites to report crime, including trafficking. The government reported receiving a total of 180 calls related to trafficking in 2024 via its Crime Stoppers hotline and website; 113 were referred to the NZP and 67 to INZ. The government funded a hotline to report migrant exploitation, which received 3,521 calls in 2024; however, no trafficking cases were identified. Workers could report complaints through MBIE’s employment rights and migrant exploitation hotlines – the latter of which had interpreters available in eight languages. Workers could also report complaints through a website to MBIE staff who referred cases to a triage team, who then filed reports to the appropriate law enforcement entity, such as NZP or LI. However, there were previous reports this system was ineffective, with authorities not investigating urgent complaints in a timely manner or not referring cases to investigators.

Observers previously reported that the government’s policy of attaching migrants’ visas to designated employers in specific industries increased trafficking risks and prevented some workers from leaving exploitative conditions for extended periods of time. The Accredited Employer Work Visa (AEWV) program allowed accredited employers to hire migrant workers. In August 2024, a report released by an independent human rights commission noted that some workers participating the AEWV scheme experience indicators of forced labor, including fraudulent recruitment and underpayment or withholding of pay. A government report previously acknowledged the visa program’s shortcomings and provided ten recommendations; the government made public its progress on meeting the recommendations outlined in the report.

The government continued to offer a six-month Migrant Exploitation Protection Visa (MEPV) to enable exploited workers whose visa was tied to their employer or that were exploited to obtain alternative employment and remain in New Zealand while authorities investigated their cases; the government issued 2,467 MEPVs in 2024. For comparison, the government reported issuing 1,467 MEPVs in the previous reporting period between April 2023 and March 2024, noting this data may include duplicate cases between January 2024 and March 2024. Nonetheless, some advocates said the MEPV did not fully address exploitation facilitated by employer-linked visas and some workers were potentially deterred from seeking an MEPV if they held a visa longer than six months. Civil society groups noted six months was an insufficient amount of time for some victims to recover from exploitation and seek sustainable new employment. In October 2024, the government removed the option for victims of migrant exploitation to extend their MEPV visa by an additional six months. The law prohibited individuals or companies from charging employment premiums, such as recruitment fees; labor inspectors could initiate proceedings in the Employment Relations Authority to recover premiums and seek a penalty against violators, although authorities did not report taking such action during the reporting period. Observers previously reported concern that penalties prescribed to unscrupulous employers in employment courts were often not significant enough to deter exploitative practices and the employers could continue operating under a new company.

The government reported funding and facilitating anti-trafficking training for foreign governments. The government did not undertake efforts to educate buyers on the possibility of sex trafficking in commercial sex. The government reported providing training related to child sexual exploitation to some diplomatic personnel, but did not provide anti-trafficking training to all diplomatic personnel.

Trafficking affects all communities. This section summarizes government and civil society reporting on the nature and scope of trafficking over the past five years. Human traffickers exploit domestic and foreign victims in New Zealand. Foreign men and women from Southeast, South, and East Asia, the Pacific, North Africa, and some countries in Latin America are vulnerable to forced labor in New Zealand’s agricultural, dairy, construction, horticulture, viticulture, fishing, food service, liquor retail, technology, hospitality, transport, and domestic service sectors. Unregulated and unlicensed immigration brokers operating in New Zealand and source countries, particularly in Bangladesh, India, China, and the Philippines, facilitate trafficking by assisting in the process to issue visas to victims. Traffickers may also coerce migrant workers into forced criminality in the cannabis industry. Migrant children, some as young as nine years old, employed in New Zealand on entertainment visas reportedly experience indicators of forced labor, including inadequate housing conditions, neglect of medical and dental care, lack of consistent education, and denial of proper wages. Some foreign workers are charged excessive recruitment fees and experience unjustified salary deductions, non- or under-payment of wages, excessively long working hours, restrictions on their movement, inadequate accommodations, passport retention, and contract alteration. Civil society and the media continued to report hundreds of migrant workers received valid AEWV tied to a single employer and traveled to New Zealand, only to discover the job was either nonexistent or unavailable. Some migrant workers spent thousands of dollars on agents for visas and relocation costs, and were left stranded, unemployed, and unable to change contracts to new employers or industries, putting them at increased risk of exploitation, including labor trafficking. Civil society reported that some of these individuals were trafficking victims that were exploited upon arrival. Some employers force migrants, whose visas are often tied to their employer, to work in job conditions different from those promised during recruitment and use intimidation tactics and false information about immigration laws to prevent victims from seeking assistance.

While experts assessed the PRA – which decriminalized commercial sex for adult New Zealand residents – overall increased protections for those who willingly engaged in commercial sex, traffickers continue to target vulnerable populations such as children, migrants, and adult victims of domestic and family violence for exploitation in sex trafficking. Traffickers utilize Section 19 of the PRA, which prohibits non-residents from legally working in the decriminalized commercial sex industry, to threaten deportation or other adverse action from law enforcement to deter migrants in commercial sex from reporting verbal or physical abuse, unwanted or unsafe sexual practices, or non-payment of wages. The PRA also does not provide protections for adults – including New Zealand nationals – engaged in “non-contact” forms of commercial sex, such as live-streaming or “camming,” which traffickers may also use to exploit potential sex trafficking victims. Young Māori are at high risk of sex trafficking, and in particular, Māori girls and young women are significantly overrepresented among victims who are sexually exploited. Foreign women from Asia and South America in commercial sex are at risk of sex trafficking, especially those who do not speak English and who work in private homes and informal or suburban environments where they are more isolated from service providers. Some international students and temporary visa holders are at risk of sex and labor trafficking, including young migrant women engaging in commercial sex and migrant workers employed in academia. Immigration brokers and unscrupulous brothel owners subject some migrants to conditions indicative of sex trafficking, including non-payment of wages, withheld passports, physical or sexual abuse, threats of deportation, monitored movements, limited access to medical care or other social services, and excessive working hours. Some migrants are required to pay fines, bonds, recruitment and other fees to brothel operators or brokers, which make them vulnerable to debt-based coercion. Traffickers exploit victims within close-knit communities based on familial relationships, ethnic background, or country of origin, creating additional barriers to reporting, especially for communities that may distrust law enforcement officials. Children residing in some Pacific Island and Southeast Asian countries are at risk of exploitation in New Zealand through intercountry adoption pathways, especially countries not party to the Hague Convention.

Some gang members, boyfriends, family members, or others exploit young children and teenagers in sex trafficking by facilitating, purchasing, or forcing them to engage in commercial sex acts. Gang members may also exploit New Zealand nationals in debt bondage by manipulating unlawful substance use and dependencies or threats to family members. Experts suggest the prevalence of forced commercial sex among New Zealand women is significantly under-reported and under-detected due to fears of criminal penalization.