D2 Redacted AI Forum feedback.pdf

Comments by

to the

Ministry of Business, Innovation and Employment (MBIE)

on

New Zealand’s
Strategy for Artificial
Intelligence

23 April 2025

CONTACTS
s 9(2)(a)

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Document Contents:
This document provides an overview of our comments and some future focused vignettes.

In addition we have included separately in the email:
•  s 9(2)(a)
detailed comments (University of Waikato and AI Forum Executive
Council member)

The full response from our Kāhui Māori has been provided separately.
Summary
The strategy is based on the OECD AI principles, providing a well-structured and robust
direction. Our comments are intended as positive and supportive, and overall there was a
favourable response to the content.
However, the strongest two concerns, common amongst the Executive Council responses,
were about the strength of the vision and relatively slow pace of progress or ambition.
Stronger vision:
A clear articulation of what we hope Aotearoa New Zealand to be known for in the AI realm
will provide a strong anchor point to pull the whole strategy together. This could be
something like ‘Leading in trustworthy AI’.
A stronger and clearer vision will encourage organisations across New Zealand to be more
excited to contribute to shaping the future of AI. We suggest:
•  Clear support from the government with a more ambitious vision that encourages us to
build AI in New Zealand, not just use it.
•  Set clear goals for different sectors, so that everyone knows where AI can make a
difference, with a clear and detailed plan to grow New Zealand’s economy through AI.
•  Support for a strong AI ecosystem, with companies, researchers, communities (including
Māori), and global partners working together. Leverage the existing capabilities to build
and invest in a national AI ecosystem where industry and research organisations can
work together more effectively. New Zealand already has a strong foundation in AI
research and development, and with the right support, it can drive innovation, create
jobs, and deliver real economic benefits.
By way of example, we have recently reviewed our own strategy and the AI Forum’s new
vision that will be announced shortly is:
Leading AI for a thriving Aotearoa
Innovative + Responsible + Inclusive
Be more ambitious and use more examples
Be more ambitious in the impact and scope of the strategy, for example:
•  Elevate AI to a national priority
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•  Alongside acknowledging AI technologies developed by others, create a focus on the
creation of world-class AI here in New Zealand.
•  Show that AI is an important priority for the government demonstrating it is worth the
investment from the private sector and overseas
•  While we should invest in attracting talent, we currently have a problem retaining it. This
is an area that the government could impact very quickly.
•  Upskilling our existing workforce is key to our success, and we need to be more
ambitious about it. For example, an incentivised programme designed as a scalable
learning experience, augmented with business partners and business mentoring
networks.
•  Strengthen the desired outcomes and focus, for example:
From:
NZ’s AI R&D capabilities deliver benefits for New Zealanders

To:
New Zealand’s AI research and innovation capabilities are world-class,
collaborative, and focused on delivering social, economic, and environmental benefits for
all New Zealanders.

•  Adopt outcome driven monitoring, taking the focus off funding and moving it to results.

Summary Comments
Opportunity vs Risk
Generative AI brings huge potential for tackling Aotearoa New Zealand’s long-standing
economic challenges, such as stagnating GDP and declining productivity growth, by
fostering innovation and efficiency across sectors. To make the most of this opportunity, we
need to strike a careful balance – recognising the risks tied to AI while embracing its
benefits.
Responsible development and governance of AI are key to addressing ethical concerns,
ensuring fairness, and preventing misuse. At the same time, being overly cautious could
mean missing out on opportunities that could position us as a global leader in AI.
By investing in education and training, fostering broad collaboration, and aligning with
international standards, we can build an AI ecosystem that reflects our values while driving
maximum benefits to our economy. Moving forward thoughtfully, rather than with fear, will
help ensure that AI drives growth, empowers people, and supports sustainable progress.
Practical step - Adopt Outcome-Driven Monitoring:
Measure impact not by the amount of funding allocated but by progress in research
collaboration, workforce readiness, ethical deployment, and cross-sector adoption. For
example:
1.  Remove insurmountable barriers to adoption: Stop looking for perfection
•  When evaluating the risk of adopting AI technologies, also ask: What is the risk of not
adopting AI? What is the risk of maintaining a current system that is failing to deliver,
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when the AI alternative may not be perfect but is demonstrably better than the
system we currently have?
•  Ask for perfection but be prepared to accept something that is better (but not perfect)
along on the way. In health, outcome risk evaluation would include the cost of non-
adoption, lost efficiency, and missed clinical benefits (poor health outcomes).
2.  Retask existing national leadership groups — such as the National AI and Algorithm
Expert Advisory Group —from responsive governance to active enablement of AI. With
clear deliverables hat are regularly monitored. For example, providing practical pathways
to adoption in Healthcare so that important advancements progress beyond proof of
concept and into actual adoption.
3.  Refocus procurement functions to support the adoption of local (and smaller) innovations
4.  Upskill our existing workforce, especially key decision makers in AI literacy and use.
Aotearoa New Zealand’s AI Ecosystem
Aotearoa New Zealand should broaden its investment in the technology ecosystem to
become a more attractive destination for innovators, entrepreneurs, and investors.
Strengthening infrastructure like applied AI research centres and fostering cross-disciplinary
collaboration between researchers, domain experts, and industry leaders are key steps.
To optimise the economic and social benefits of AI, we should consider prioritising
investments in the AI ecosystem that focus on application-driven innovation specifically. By
channelling resources into areas such as adapting, fine-tuning, and testing existing
foundation models in practical settings, we can ensure that AI research directly supports
tangible, impactful applications aligned with local needs and priorities.
National initiatives alongside support for local tech companies taking on global markets, will
enhance Aotearoa New Zealand’s appeal as a hub for advanced AI development. By
cultivating an ecosystem that enables experimentation, lowers barriers, and fosters
innovation, we can position ourselves as a leading destination for building and scaling
cutting-edge AI solutions that benefit both domestic and international markets.
Practical step - Adopt key actions that can be implemented by leveraging existing
resources:
•  Activate existing agencies like MBIE and StatsNZ, and organisations like the AI Forum
and AIRA and AI Institutes at Universities, to deliver components of the AI strategy
without requiring new bureaucracies or funding streams
•  Form a national network of AI research hubs using existing institutions including
Universities and CRIs (under the new PROs).
•  Tying in with the work being done to foster international research partnerships in key
sectors and support sandboxing and modelling initiatives, especially in regulatory
spaces, for example to explore the impact of different approaches to IP.
Local Compute
Aotearoa New Zealand should continue to invest in and partner to deliver modern data
centres as a strategic priority for advancing AI. Data centres provide critical infrastructure
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that reduces latency and enables faster processing, which is essential for refining existing AI
models and developing impactful applications.
This will be even more important in the future to enable affordable and efficient operation of
applications. For a small yet globally connected economy like Aotearoa New Zealand, data
residency is another key advantage, ensuring compliance with local regulations while
fostering trust in AI systems. There is also potential for us to extend this capability to support
our Pacific Island neighbours.
By encouraging data centre construction and scaling renewable energy production, the
country can position itself as a technological hub that delivers AI solutions tailored to
domestic needs while meeting international standards, further solidifying its role in global AI
advancement.
Scaling Aotearoa New Zealand AI
Building on the work already underway where we are informing international standards, for
example participation in building the ISO Standards as referenced in the document, we
should recognise that adopting customised or unique standards and regulations forgoes
alignment with internationally recognised frameworks that will allow Aotearoa New Zealand
to more easily take advantage of global AI capabilities.
Unified standards simplify access to advanced AI tools and technologies and enhance the
ability of our locally based companies to export their innovations, ensuring they are
compatible with international markets and value chains.
This approach is not at odds with recognising and protecting our rich heritage and
uniqueness. The AI Forum sees the incorporation of Te Tiriti o Waitangi as a strength not a
weakness.
Challenging our technologists to be inclusive and solve for challenges like cyber security,
data sovereignty, cultural recognition, online safety and data privacy strengthens our
reputation and the quality of our digital products.
Access, Adoption and Skilling
Access, education and skilling are critical to drive AI adoption and inclusion both in and
beyond the workplace. The government can play a central role in this effort by investing in
comprehensive AI education programmes tailored to industry professionals, public sector
employees, and the wider population.
For workers, the emphasis should be on equipping them with the skills needed to integrate
AI into their current roles while preparing them to navigate future job transformations driven
by AI. Promoting career mobility within organisations also aids in ensuring the benefits of AI
are shared amongst New Zealanders. This can be achieved through subsidies for training
programmes, partnerships with educational and tech institutions, business and mentoring
associations, and incentives for businesses that adopt AI-enhanced workflows.
For the public, we should actively promote awareness campaigns to clear up
misunderstandings about AI and build AI literacy, knowledge and trust in its benefits.
By highlighting real-life examples of how AI is improving public services, the government can
lead by example, demonstrating its reliability and benefits. Educating communities about its
practical applications, rather than focusing on technical jargon, can go a long way.
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Special efforts to include groups like seniors or those with limited tech access will make AI
adoption more inclusive, showing that AI is a technology for everyone, not just the experts.
AI has the potential to exacerbate the digital divide, reinforcing the importance of addressing
issues with digital access and extending education through existing community organisations
like Tū Ātea, Fibre Fale, ACE Aotearoa, and Te Hapori Matihiko.
By giving people the confidence and knowledge to use AI in their lives, we can unlock its full
potential while ensuring no one gets left behind.

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Industry Vignettes – a view into the Future
Creative Industries by 2030
Encompassing Film, Media and Advertising, Games, Music, Publishing
The world already knows New Zealand for its creativity and innovation. Our creative sector and its
people are the ones who tell our unique stories for us and, through technology, for others. We need
our creative industries to be strong and sustainable so that our future generations will know about
Aotearoa from us, not just the view of the world as controlled by Silicon Valley.
We will use New Zealand’s connectedness as a competitive strength to develop highly col aborative
AI centres of excellence that attract creative individuals, industry and learning institutions to work
together to take our creative AI to the world.
Underpinning an industry that is worth more than $4.1 Billion exports annually (2022) and growing at a
compound annual average of 9% since 2015, we plan to create a trusted quality mark the New
Zealand Creative Industries, will be recognised around the world for AI systems and outputs that are:
1.  Trusted - ethical AI models, built on foundations of transparency and respect, are
distinguishable as having been ‘created in NZ’, growing Aotearoa’s existing international
reputation for our creativity and innovation.
2.  Unique - we’ll produce creative outputs that celebrate what makes us different, with a focus
on Te Ao Māori. Rather than trying to compete on size and scale, we’l  focus on being
creatively and culturally distinctive.
In order to get there we need to reward, respect and recognise original creative work. Selling trusted
and unique AI to the world will lead New Zealand to being a net exporter of creative IP.
•  Support the establishment of a new regulatory testbed that provides a space for an industry-
informed model to bring tangible scenarios and creative sector experiences to regulation
development
•  Harmonising of IP regulations and enforcement to protect this valuable industry
•  Improve visibility of AI use-cases in our sector through building our community of practice

Data Sources: https://wecreate.org.nz/wecreate-creative-export-explainer/ &
https://aiforum.org.nz/reports/ai-blueprint-for-aotearoa-new-zealand/

Architecture Engineering and Construction (AEC) by 2030
Infrastructure in Aotearoa New Zealand was valued at $287 billion (2022), with investment running at
5 to 6.5% of GDP for the last 20 years.
By 2030, the AEC sector in Aotearoa New Zealand aspires to be at the forefront of developing,
adopting and implementing innovative solutions that streamline the delivery of critical infrastructure
projects, leading to improved productivity in the sector and adding real value for all taxpayers,
contributing to healthy, consistent GDP growth and positively impact the nation’s economy.
Boosting productivity and enhancing planning and building for climate resilience and adaptation, this
vision will be supported by a fully defined AI innovation ecosystem, expediting the awareness,
adoption, and innovation of AI within the sector across the nation.
It includes the establishment of a national framework of Data and AI Governance, Standards, and
Policies that enable the steady development and implementation of responsible AI solutions. Work is
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already underway through New Zealand's participatory involvement in the ISO Artificial Intelligence
Committee, allowing us to influence global AI standards, benefiting the AEC sector and others.
AI will also play a substantial role in the AEC sector’s research and development initiatives, with the
ambition that over 40% of all projects involve AI, accelerating research, testing and speed to market.
This integration of AI into the sector signifies the country’s commitment to responsibly embracing
advanced technology to boost productivity across the sector and Aotearoa.
Current challenges that collectively hinder the ability to scale AI's value in addressing repeatable
problems and affect the commercial viability and growth potential within the AEC industry:
•  The rapid advancement of AI tools is outpacing the capacity of individuals and organizations
to learn and effectively utilize them. This results in insufficient support for developing
necessary AI-related skills and a pervasive apprehension towards AI adoption.
•  The rapid progression of technologies hinders the initiation and development of AI projects,
especially for SMEs, due to economic pressures and an uncertain project pipeline.
•  The escalating costs of running AI models, combined with rising expenses for cloud
computing and energy, and limited data storage options, further exacerbate these challenges
•  Data sovereignty issues and a lack of long-term vision for infrastructure projects impede
strategic investment in AI solutions.
•  High compliance burdens from forthcoming regulations and minimal progress on data
standards and frameworks within the AEC industry add another layer of complexity.
New opportunities in the AEC sector, include people, skills, talent, research, innovation, commercial
environment, and regulatory and business environment:
•  High-level prompt engineering is emerging as a crucial skill in generative AI, essential for
professionals across all sectors, including AEC.
•  Upskilling programs for board members and businesses are necessary to enhance
understanding of AI's potential and challenges, enabling informed decision-making and agile
business model innovation.
•  The rapid advancement in AI technology, combined with quantum computing and IoT,
presents increased business value and access through low-code and no-code solutions.
•  AI foundation model ownership is becoming more feasible, encouraging organizations to
develop and control their AI models.
•  Public-private partnerships and international business treks aim to create new global AI in
AEC partnerships and inspire New Zealand AEC innovators to scale in multiple markets.
•  New Zealand's participatory involvement in the ISO Artificial Intelligence Committee allows
the country to influence global AI standards, benefiting the AEC sector and others.
•  Incorporating AI into government procurement for large AEC projects could drive innovation
and efficiency, further enhancing the sector's capabilities

Education Sector
The future of education in Aotearoa New Zealand is one where learners are equipped, educators are
empowered, and our nation excels in educational innovation, harnessing Artificial Intelligence (AI)
capabilities.
By championing AI integration to foster excellence in learning and teaching we will secure Aotearoa
New Zealand's position as a global leader in innovative education.
B 2030, AI will enable our education sector to:
●  Facilitate inclusive and equitable access to learning that is driven by a Te Ao Māori lens.
●  Provide personalised learning that enhances engagement and lifts outcomes for students.
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●  Automate administrative tasks, freeing up educators’ time to focus on teaching.
●  Re-evaluate teaching, learning and assessment based on the requirements of future employment
and societal contexts.
We are committed to working towards these goals having established a National Taskforce to
develop strategic plans, monitor AI implementation, and ensure alignment with national educational
goals including developing teacher education; and a Community of Practice for collaboration among
more than 400 educators, AI practitioners, and policymakers who meet regularly to upskill and share
the latest developments.
Environment
By 2030, the cost of obtaining additional data for AI systems will be reduced, allowing for
better-informed environmental decisions. AI will assist in addressing various environmental
challenges, such as measuring biodiversity, and will support more effective forward planning.
Data will be made accessible through AI, enabling people to make informed environmental
decisions, and global connections will be strengthened by benchmarking environmental data
against international standards.
Systems of data collection wil  respect Māori data sovereignty and our unique cultural
environment. Our goal is to maximize our global environmental contribution rather than
compete against it.
Why should the Environment be a key focus area for Aotearoa?
The environmental sector in Aotearoa New Zealand has substantial strengths across various
dimensions. It already boasts significant environmental science and research groups that
integrate technology into their sustainability efforts.
The commercial environment is vibrant with ongoing innovations in tech and the
environment. The sector leverages its clean-green image, emphasizing sustainable food and
clean tech solutions, with opportunities for partnerships in precision farming.
The business and regulatory environment benefits from a smaller population, allowing for
quicker mobilization of initiatives. The country has abundant renewable energy resources
and rich natural assets.
Additionally, we are well-positioned to act as a test bed or pilot country for global
environmental opportunities. Schools are dedicated to providing individuals with the
necessary skills to contribute productively to society.
Getting there
Shifting demand towards AI-produced solutions, emphasizing speed, flexibility, and sensing
capacity, and attracting entrepreneurial talent, partnerships with cutting-edge overseas
entities and attracting investment are all vital in commercialising the potential in this space -
but the success of our CleanTech industry is testament to the potential.
Agriculture
In 2030, Aotearoa New Zealand will be a world-leading hub for responsible AI innovation,
recognised globally for harnessing AI to enable a prosperous, inclusive, and equitable future.
Our ambitious goals for the next five years include being in the top 30 of the Government AI
Readiness Index, top 25 of the Global AI Index, and top 10 in OECD productivity rankings. To achieve
this, we must start now and move at speed, implementing specific actions and policies that drive us
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towards these targets. Achieving these milestones will significantly boost New Zealand's GDP, create
high-value jobs, and position us as a global leader in AI innovation.
What we have learned:
"Data is the new fertiliser—growing smarter decisions, healthier soils, and stronger farms”
"When farms thrive, communities prosper—AI brings us forward together”
"Doubling primary sector GDP starts with connecting paddocks and empowering farmers”
What we have achieved
We have laid the groundwork for significant change:
Building industry collaborations across the agricultural sector putting in place the foundation for a
“daisy chain of success”
Global leadership in Standards: New Zealand is now a voting member in the ISO Artificial Intelligence
Committee, allowing us to influence global AI standards that meet local needs.
We are responding to the opportunity to build prototype with the potential to enhance agricultural
exports in a cross-border collaboration with Singapore.

Sources:
https://aiforum.org.nz/reports/ai-blueprint-for-aotearoa-new-zealand/
https://aiforum.org.nz/reports/ai-blueprint-2025-update-charting-new-zealands-ai-powered-future/

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