17 October 2025
45 Pipitea Street, Wel ington 6011
Phone +64 4 495 7200
dia.govt.nz
Shar
fyi-request-32342-
[email address]
Tēnā koe Shar,
OIA request 25/26 0325 Request for information on Citizenship by Grant
Thank you for your Official Information Act (Act) request received by the Department of Internal
Affairs (Department) on 19 September 2025.
You requested –
Information regarding the ‘Status of Citizenship by Grant applications by month received’
on the data.govt.nz website: https://catalogue.data.govt.nz/dataset/status-of-citizenship-
by-grant-applications-by-date-received-at-dia/resource/712409ae-d154-4ac9-a511-
75627d4a9eb0
1. Can you explain on what data has been collected for publishing this status data.
2. Can you provide Aug 2025 data for CBG application received.
3. Can you provide how many numbers of CBG application received were approved for
monthly of AUG 25.
4. As per your graph status what metrics or factors made you to prioritize those CBG
application received in month of Aug 25 to prioritize over other applications and
approved the same month.
5. If it hasn't been approved is your status graph data published wrong.
6. What is the process of Independent verification on the CBG approval and how does
dia manage no bias in the system of approval or decisions on CBG Application s.
On 1 October 2025 you were contacted via email to clarify what you meant by “independent
verification on the CBG approval” and “bias in the system of approval or decisions” in question
six.
You replied on the same day with the fol owing -
•
By “independent verification on the CBG approval”, I am referring to any processes,
audits, reviews, or oversight mechanisms that are in place to ensure that each CBG
approval is accurate, justified, and compliant with policy, independently of the original
approving authority.
•
By “bias in the system of approval or decisions”, I am referring to the possibility of any
actual or perceived conflicts of interest, structural or procedural biases, or systematic
factors within the approval process that may influence, favour, or disadvantage
particular applicants or outcomes. I am particularly interested in understanding any
independent review or mechanisms that ensure each decision is fair, accurate, and free
from undue influence, considering the human factors involved.
In response to your request, I can provide you with the fol owing information.
Question one
The data reflects the status of Citizen by Grant (CBG) applications based on the month they
were received. It is updated at the beginning of each month. Accordingly, the current graph
shows the status of al applications received up to the end of August 2025 as at 1 September
2025. As the data is regularly updated on the website, please find attached Appendix A which is
a snapshot of the data at the time of this response.
Question two
During the month of August 3,467 applications were received. This figure is displayed in the top
bar of the graph available online, which presents monthly application volumes. I refer you to
Appendix A attached.
Question three
In August 2025 31 CBG applications were both received and approved.
Question four
The 31 applications referenced in question three were submitted by Samoan citizens and were
processed under the Citizenship (Western Samoa) Act 1982, which fol ows a distinct pathway
with a shorter queue than standard CBG applications.
Question five
The data and graph have been confirmed as accurate. They reflect the status of applications as
at 1 September 2025.
Question six
For the purpose of this response, we have interpreted your request to relate to CBG applications
which are approved under delegated authority by officials.
The process for approval of CBG applications has several checks and balances to specifically
address the risk of bias on the part of officials assessing an application for grant of citizenship.
The process described below is fol owed for most applications -there are a small number which
have a slightly different process as they have fewer assessment criteria but have similar checks
and balances.
Page 2 of 4
link to page 3 link to page 3
Applications are assessed by Life and Identity Services Officers (LISOs) using an online Case
Management Software, which allocates and tracks applications, and records decisions on each
aspect. Each application is assessed by one LISO and then referred to a different experienced
LISO for a second check. The second check allocation is automated and random as part of our
assurance process.
I refer you to Appendix B attached alongside this response for
Process – Validate citizenship by
grant applications. This document highlights the second checking aspect which ensures
consistent application of policy. Second checking of applications is in place to provide
confidence in the integrity of the system.
An independent Business Assurance team also reviews a sample proportion of work to check
compliance with relevant policies and procedures.
To avoid the risk of bias in individual assessment, applications are allocated to LISOs
automatical y by the system for the first check or the second check/verification step. The LISO
cannot choose to assess or check a particular application. In addition, if a LISO identifies a
personal connection to the applicant, they are required to refer it to their Team Leader for
reallocation.
For CBG there is limited discretionary/processing approval. Many of the requirements are
factually based, for example the applicant either has a residence visa or does not, the applicant
has been in the country for the required period of time, or they have not. Either a person meets
the requirements in the legislation, or they don’t. These requirements are contained within
Citizenship Act 1977
1 legislation which is available online.
The assessment of each requirement of an application (for example, holding the appropriate
residence class visa, presence in New Zealand, good character) is assessed separately, and the
system records the specific, objective, reason that an applicant meets or does not meet a
specific requirement.
There are some areas where an applicant’s ability to meet a requirement is not always clear cut.
For example, some applicants may have information to be assessed relating to the good
character requirement (for example, historic convictions) or their intention to remain in New
Zealand.
To support fair and accurate decision-making the Department has clear policies that apply to
assessment. Guidance for applicants and officials is published online in the New Zealand
Citizenship Guidance Document
2 supported by more detailed operational policies.
Again, the reasons for a LISO’s assessment about the applicant are recorded in the application,
and then these reasons are reviewed by another LISO as part of the verification step. Where the
LISOs are unsure or disagree, there is a process to seek advice from a group of experienced
col eagues. The question and advice are recorded to support transparency and consistency.
1 Link to Citizenship Act 1977 -
http://www.legislation.govt.nz/act/public/1977/0061/latest/whole.html
2 Link to Citizenship Guidance Document -
https://www.dia.govt.nz/diawebsite.nsf/Files/Citizenship-
2023/$file/Citizenship-Guidance-June-2024.pdf
Page 3 of 4
Some applications are not approved under delegated authority and are referred to the Minister
for a decision. I refer you to Appendix C attached alongside this response
for
Policy – Applying
Administrative Law to Citizenship applications. This document goes into detail about how the
principles of Administrative Law are applied for citizenship by grant applications.
It also excludes grants made as of right under section 10, section 7A, and the Citizenship
(Western Samoa) Act 1982, which do not involve discretionary approval. While these may
appear in statistical reporting, they are not subject to the approval processes described here
As this information may be of interest to other members of the public, the Department has
decided to proactively release a copy of this response on the DIA website. Al requestor data,
including your name and contact details, will be removed prior to release. The released
response will be made available here:
https://www.dia.govt.nz/Official-Information-Act-
Requests-2.
You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at www.ombudsman.parliament.nz or
freephone 0800 802 602.
Ngā mihi
John Crawford-Smith
Principal Advisor
Regulatory and Identity Services
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