Public Annotation: Crown Law's Cautious Testing of Generative AI Tools – A Step Toward Transparent Public Sector Adoption

Posted by Erika Whittome on fyi.org.nz, 12 October 2025.

This Official Information Act (OIA) response from the Crown Law Office, dated 9 October 2025, offers a rare glimpse into the early-stage integration of generative AI (GenAI) tools within a key New Zealand government legal agency. Submitted on 1 October 2025, the request sought details on AI tool purchases, costs, and subscription terms—prompting a swift, full disclosure that underscores Crown Law's commitment to transparency amid the nation's evolving AI governance landscape.

Key Disclosures
Crown Law revealed it is actively testing three GenAI productivity services in "contained test groups," with no broad organizational rollout to date. These tools are:
- **Microsoft Copilot 365**: Integrated into the agency's existing Enterprise Agreement with Microsoft. Five individual user licenses were activated as part of the September 2025 annual renewal, costing $2,551.55 in total. Licenses can be deactivated anytime but are locked into the agreement until September 2026.
- **Google Gemini**: A standalone subscription started in July 2025, at an annual cost of $443.88. It can be cancelled with one month's notice and is not expected to extend beyond December 2025, potentially avoiding the full-year expense.
- **ChatGPT Plus**: Similarly initiated in July 2025 for $410.40 annually, with the same short-term horizon and cancellation flexibility.

No other tools (e.g., AI Governance Deck or IVO AI, as queried) were mentioned, and total testing costs appear modest at around $3,405 for the year—though indirect expenses like staff training remain undisclosed. The response emphasizes controlled, low-risk experimentation, aligning with the Public Service AI Framework's principles of accountability, safety, and human-centered design.

Broader Implications
This disclosure is timely, arriving just months after the launch of New Zealand's AI Strategy on 8 July 2025, which promotes "light-touch" regulation to foster innovation while mitigating risks like bias and privacy breaches. For Crown Law—a steward of public prosecutions and legal advice—AI's potential in tasks like document review or research could streamline operations, but it raises questions about equity, especially for Māori claimants under Te Tiriti o Waitangi obligations. The agency's proactive note on potential website publication (with redactions) signals intent to build public trust, though requesters have 10 working days to object.

As GenAI adoption accelerates across the public sector, this OIA highlights the value of targeted transparency requests in holding agencies accountable. It complements the Government's emphasis on OECD-aligned principles, ensuring AI serves New Zealanders without eroding democratic safeguards. Future OIAs could probe deeper into evaluation metrics, bias audits, or workforce impacts to track progress.

For context, see the response PDF above. If you're inspired to submit your own OIA on AI in government, fyi.org.nz makes it easy—tools like these requests are building a vital public record.

*Erika Whittome is a transparency advocate tracking governance in Aotearoa.*

---

Supporting OIAs: Other Requests on AI Tools and Usage in NZ Government Agencies
To deepen understanding of GenAI trends, I've compiled a list of related OIAs from fyi.org.nz, focusing on similar disclosures about tools, costs, trials, and policies in public sector entities. These were identified through a comprehensive search of the site, prioritizing 2024–2025 requests with successful responses or ongoing relevance. Each includes a brief summary, status, and link for cross-reference.

| Request ID | Title | Agency | Submission Date | Status | Summary |
|------------|-------|--------|-----------------|--------|---------|
| 32435 | AI software and AI tools at the MoH | Ministry of Health | 1 October 2025 | Awaiting response | Mirrors the Crown Law request, seeking details on AI tool purchases, dates, costs, and licenses (e.g., ChatGPT, Copilot) at Health NZ—ideal for comparing health sector adoption. [Link](https://fyi.org.nz/request/32435-ai-soft...) |
| 30431 | ChatGPT, Claude, Gemini, and other LLM usage | Ministry of Business, Innovation & Employment (inferred from context) | 15 March 2025 | Successful | Requests records of interactions with GenAI tools like ChatGPT, Copilot, and Gemini, including usage logs and policies—reveals early 2025 testing patterns across agencies. [Link](https://fyi.org.nz/request/30431-chatgpt...) |
| 30774 | Use of Artificial Intelligence in Ministerial Communications | Department of the Prime Minister and Cabinet | March 2025 | Successful | Inquires about AI (e.g., ChatGPT, Gemini) in drafting ministerial docs during the ASMS strike—highlights risks in high-stakes comms and governance gaps. [Link](https://fyi.org.nz/request/30774-use-of-...) |
| 31232 | Use of AI and data privacy when processing submissions on the Regulatory Standards Bill | Ministry for Regulation | 6 June 2025 | Successful | Details AI use in analyzing submissions, including tools for summarization and privacy assessments—discloses policy docs and official discussions on ethical deployment. [Link](https://fyi.org.nz/request/31232-use-of-...) | [Response PDF](https://fyi.org.nz/request/31232/respons...) |
| 31575 | Draft Versions of "New Zealand's Strategy for Artificial Intelligence" | Ministry of Business, Innovation & Employment | 19 June 2025 | Successful | Seeks drafts of the national AI strategy, including attachments on tools and frameworks—provides backstory on government-wide GenAI guidance. [Link](https://fyi.org.nz/request/31575-draft-v...) |
| 27753 | Artificial intelligence to analyse submissions | Ministry of Justice | 22 July 2024 | Successful | Explores AI/GenAI in submission analysis, audits, and plans—early indicator of tool trials in policy processes. [Link](https://fyi.org.nz/request/27753-artific...) |

These requests form a growing mosaic of AI transparency efforts.