Kia ora koutou,

Under the **Official Information Act 1982**, I request machine-readable information about ACC’s **expenditure on external legal services** used to defend, manage or represent ACC in dispute processes (e.g., **ICRA, Fairway, District Court/High Court** matters) for the five most recent financial years **2020/21–2024/25**.

This request focuses on information **held in ACC’s finance/ERP systems** and related procurement records. It is made in the **public interest** to improve transparency around representation in claimant disputes and cost-effectiveness of external legal use. See ACC’s reported claims-handling costs ($**662m** in 2023/24) and the “consulting and other professional services” line item, which indicate relevant categories exist within ACC’s accounts.

Part A — Finance/ERP data extract (CSV under s 16)

Please provide a **CSV export** from ACC’s finance/ERP for the period **2020/21–2024/25** containing **all payments to external legal suppliers** (law firms/barristers/advocates) for dispute, review or litigation work, filtered by the **GL account(s)** or **spend categories** ACC uses for legal services and/or litigation/appeals/reviews.

**Fields requested (where held):**

* Supplier legal name; NZBN (or other supplier ID)
* Invoice number; invoice date; payment date
* Line description / matter reference (with personal identifiers redacted if required)
* Amount (NZD ex-GST), GST, gross
* **GL Account code & description; Cost Centre; Project/Work Order; Business Unit**
* Any **matter type** or tag used (e.g., ICRA, Fairway, District Court, High Court, Tribunal)
* (If held) **Claim number** (I accept redaction to protect third-party privacy; aggregated totals per supplier/matter type suffice)

Format: Please provide as **CSV** (s 16 OIA). If multiple GL codes are used for legal services, include **all relevant codes** (see Part B).

Why this is held: ACC has previously released **ERP extracts of supplier payments** via FYI (showing supplier names/amounts — including *McCaw Lewis Limited*) demonstrating such data can be exported without per-file collation. ([FYI][1])

Part B — Chart of accounts & coding used for legal spend

Please provide:

1. A list of **GL Account codes/descriptions** used for **external legal services** (including litigation/review/appeal costs) during **2020/21–2024/25**.
2. Any **Cost Centres/Programs/Projects** commonly used to record spend on **ICRA, Fairway, or court appeals**.
3. Any **data dictionary** or field definitions needed to interpret the Part A CSV.

Part C — Panel/contracting arrangements and supplier list

Please provide:

1. The **current list of panel or approved external legal suppliers** engaged to act for ACC in reviews/appeals/disputes, and the **date ranges** of any panel or contract arrangements (including when ACC established its own external legal panel for AC Act litigation). ([FYI][2])
2. Any **standard engagement terms** or **service level expectations** for these suppliers.
3. For **2020/21–2024/25**, a **summary by supplier** of **annual total paid** (fees + disbursements + GST) for dispute/litigation matters only. (If producing this summary is onerous, please provide it **by the top 20 suppliers by value** for each year.)

Part D — Breakdown by forum / matter type (aggregates)

For 2020/21–2024/25, please provide **aggregated totals** (fees + disbursements + GST) by:

Forum: ICRA, Fairway, District Court, High Court, other tribunals
Business area: (e.g., PIC/impairment, cover, treatment injury, AEP/NZDF-transferred claims)
Outcome stage: mediation/settlement; hearing; appeal (if tagged in your system)

If not held as a canned report, please produce **one-off aggregated tables** based on the same ERP/GL filters used in Part A (s 17 allows reasonable extraction).

Part E — Narrowing options (to avoid s 18(f))

If my scope is assessed as potentially requiring “substantial collation,” please **apply s 13 duty to assist** and proceed with any of the following **narrower options without delay**:

1. Limit Part A to the **GL code(s)** explicitly titled **“Legal services” / “Litigation” / “Reviews & Appeals”**;
2. Limit suppliers to a **panel list** or to the **top 20 legal suppliers by value** each year;
3. Limit to **forums** (ICRA/Fairway/courts) rather than claim types; or
4. Provide **2023/24 and 2024/25** first, with earlier years to follow.

Partial release is requested where possible.

Part F — My claim (context only)

For clarity, I have an **ICRA hearing on 16 October 2025** (Claim **#10038184163**). While this OIA targets system-level data, please note I will seek **claim-specific invoices/time entries** under the **Privacy Act 2020**. (If easier for ACC, you may provide my claim’s **aggregate external-legal total to date** in this OIA, with personal identifiers redacted.)

Administration

Format: CSV (Part A), PDF or CSV (Parts B–D).
Timeframe: Standard 20 working days; if an **extension** is needed, please advise under s 15A and provide **rolling/partial release**.
Withholdings: If any information is withheld, please **cite the exact subsection** and explain the public-interest test (s 9(1)).
Charges: Please consider **waiver** due to public interest and reuse on FYI.

Kind regards,
Spencer Gerwyn Jones

Kia ora Christopher Johnston and the OIA Services team,

Reference:** GOV-043640 (original refusal 29 Oct 2025)
Original FYI Request:** #32534 – *ACC external legal services – finance/ERP extracts, GL codes, and panel spend (2020/21–2024/25)*

Thank you for your response today. I note the refusal under s18(f) due to substantial collation across multiple teams and systems. I appreciate the invitation to refine the scope and, in the spirit of s13 (duty to assist) and **public interest transparency (s5), I am now submitting a significantly narrowed request to enable a manageable and efficient response.

This refined request removes all 2020–2022 data, eliminates per-supplier or per-invoice detail, drops all claim-level references, and focuses only on high-level aggregates and coding metadata for the two most recent financial years (2023/24 and 2024/25). It is designed to be answerable using existing reports, GL summaries, or simple ERP queries—no manual file collation required.

Refined Official Information Act Request – GOV-043640 (Follow-up)

Under the Official Information Act 1982, I request the following **aggregated and anonymised** information about ACC’s expenditure on **external legal services** used in **dispute, review, or litigation processes** (e.g., ICRA, Fairway, District/High Court) for **2023/24 and 2024/25 only**:

Part 1 – GL Account Codes & Categories (Metadata only)
Please provide:
1. A list of **GL account codes and descriptions** used in ACC’s finance/ERP system to record **external legal services** related to **reviews, appeals, or litigation** in 2023/24 and 2024/25.
- Example format:
```
GL Code | Description
720100 | External Legal – Reviews & Appeals
720200 | Litigation Counsel – Court Matters
```
2. Any **Cost Centre, Project, or Program codes** commonly associated with **ICRA**, **Fairway**, or **Court appeals** (names only—no spend data).
3. A brief **data dictionary** (if held) defining key fields (e.g., “Matter Type”, “Forum”) used in legal spend tracking.

*Format:* CSV or PDF table
*Why feasible:* This is static reference data, not transactional. ACC has released similar coding structures in prior OIAs (e.g., FYI #19876 – provider payment codes).

Part 2 – Aggregated Spend by Forum (Two Years Only)
Please provide **total annual spend** (NZD, **including GST**) on **external legal services** for dispute/litigation matters, broken down by **forum**, for **2023/24 and 2024/25**:

| Financial Year | ICRA | Fairway | District Court | High Court | Other Tribunals | **Total** |
|----------------|------|---------|----------------|------------|------------------|-----------|
| 2023/24 | | | | | | |
| 2024/25 | | | | | | |

*Notes:*
- Aggregates only—no supplier names, invoices, or claim numbers.
- Use the same GL filters as in Part 1.
- If “Other Tribunals” is not tracked, combine into “Other” or note as N/A.
- If 2024/25 is incomplete, provide YTD and note cut-off date.

*Format:* CSV or PDF table
*Why feasible:* ACC produces financial reporting for levy setting and annual accounts. High-level forum aggregates are likely available via canned reports or simple queries (per s17 OIA).

Part 3 – Top 5 External Legal Suppliers by Total Spend (Aggregated, Two Years)
For **2023/24 and 2024/25 combined**, please provide **total paid** (NZD, **including GST**) to the **top 5 external legal suppliers** (by value) for dispute/litigation work:

| Rank | Supplier Legal Name | Total Paid (2023/24 + 2024/25) |
|------|---------------------|-------------------------------|
| 1 | | |
| 2 | | |
| ... | | |

*Notes:*
- Redact supplier names **only if required under s9(2)(a)**—otherwise, release (public interest in accountability).
- No per-year or per-matter breakdown.
- Based on same GL filters as Part 1.

*Format:* CSV or PDF table
*Why feasible:* Top-supplier summaries are standard in procurement reporting (e.g., AoG panel dashboards, ACC annual report disclosures).

Administration & Grounds for Release

- **Timeframe:** 20 working days from receipt. Partial/rolling release welcome (s16C).
- **Format:** CSV preferred for tables (s16); PDF acceptable.
- **Charges:** Please **waive** under public interest (s12(2))—this data supports scrutiny of ACC’s $662m claims-handling spend and levy sustainability. Will be published on FYI.org.nz.
- **Withholdings:** If any, cite exact subsection and apply public interest test (s9(1)).
- **Duty to Assist (s13):** This scope uses your original Part E narrowing options (limit to recent years, aggregates, top suppliers, GL-based). It avoids per-claim or per-invoice work.
- **Context:** This follows your refusal under s18(f) and is structured to **minimise resource impact** while preserving public interest.

I look forward to a positive and constructive response. Please don’t hesitate to contact me to discuss further refinements.

Kind regards,
Spencer Jones
[email address]

Kia ora ACC OIA Team,

Reference: GOV-043640 (9 October 2025) and GOV-044064 (29 October 2025)
Response received: 26 November 2025

Thank you for the response of 26 November 2025, including Appendix 1 and Appendix 2.
I am submitting a short follow-up OIA to clarify several items from my original request that appear to remain unanswered, and which were not refused under any OIA provision.

---

1. Cost Centre / Project / Programme Codes

In my original request I asked for:

* cost centre codes
* project codes
* programme codes

commonly used when recording or processing:

* ICRA matters
* Fairway matters
* District Court appeals
* High Court appeals
* Tribunal matters (HRRT, ERA, etc.)
* External legal counsel engagement

These items were not addressed in either GOV-043640 or GOV-044064, and no refusal grounds were cited.

**Please confirm whether ACC holds cost centre, project, or programme codes used for the above categories.**
If none exist, please confirm this explicitly under **section 18(e)**.

---

2. Data Dictionary / Field Definitions

My request also sought:

> “any data dictionary or field description for the fields used in ACC’s systems to record external legal spend, dispute forum, matter category, or review/appeal type.”

This includes fields such as:

* **Forum**
* **Matter Type**
* **Appeal / Review**
* **ICRA / Fairway**
* **Internal Counsel / External Counsel**
* Any field used to generate Appendix 2 (26 November response)

Your response did not state whether such definitions exist.

**Please confirm whether ACC holds a data dictionary, schema, or field description for these fields.**
If not, please confirm under the relevant OIA provision.

---

3. Analysis Code 06030 (ICRA/Fairway)

Your 26 November response states:

> “ACC only uses one code to track ICRA and Fairway: 06030.”

To understand this accurately, please confirm:

* Whether **any sub-codes**, **attributes**, **tags**, or **fields** within 06030 distinguish between ICRA and Fairway.
* If such identifiers exist, please provide the field names and descriptions.
* If no internal differentiation exists, please confirm this explicitly.

---

4. Source Systems Used for Appendix 2

Please confirm which finance/ERP or legal-tracking systems were used to extract the data in Appendix 2 (e.g., TechOne, Salesforce, LAS, ECAT, other internal datasets).

This is for transparency of source systems only — not a request for raw data.

---

5. Duty to Assist (Section 13 OIA)

Given that the narrowed request (GOV-044064) demonstrates that aggregated financial data is readily available through existing GL and analysis codes, please confirm:

Can the structural metadata requested above (cost centres, project codes, data dictionary definitions) be supplied without invoking section 18(f)?

---

Kind regards,
Spencer Jones

Kia ora ACC OIA Services,

Thank you for your 9 December 2025 response (GOV-044691). I appreciate the timely reply.
However, several aspects of the response require clarification because the explanations provided appear inconsistent with both ACC’s own public reporting and previous OIA releases, and because the use of s18(e) and s12(2) in this instance raises legitimate concerns under the duty to assist (s13) and the purpose of the OIA (s4).

This reply outlines the key contradictions and requests clarification so the request may proceed on an accurate basis.

1. Claimed non-existence of cost centres, project codes, programme codes, or sub-codes

Your response states that ACC holds no codes—beyond analysis code 06030—capable of distinguishing expenditure for:
• ICRA
• FairWay
• High Court
• District Court
• Tribunal matters
• External legal counsel

This claim appears inconsistent with:

A. ACC’s own public reporting

ACC annually publishes separate performance and volume reporting for:
• ICRA
• FairWay reviews
• Decline rates
• Resolution times
• Outcomes by forum

It is not possible to generate these public metrics without some form of internal segmentation or classification structure, whether cost-centre based or metadata-based.

B. ACC’s 26 November OIA release (GOV-044064)

In that release, ACC provided separate expenditure totals for:
• ICRA ($10.7M in 2024/25)
• FairWay ($8.06M in 2024/25)

If ACC has no codes or attributes capable of distinguishing these forums, then it is unclear how these figures were generated.

C. Oracle and Med Fees Processing (MFP) system requirements

Both systems require:
• data dictionaries,
• field definitions,
• schema-level metadata,
• audit trails,

to function correctly and comply with public-sector finance and data-governance standards.

Therefore, the assertion that no definitional documentation or classification metadata exists at all is difficult to reconcile with ordinary ERP operations and with Treasury Instructions 2024 and Cabinet metadata standards (CO(02)3).

I therefore request clarification on how ACC produces segmented reporting internally and publicly if no segmentation is recorded in the ERP or associated metadata.

2. Claimed absence of a data dictionary or field-definition documentation

Your response declines the request for a data dictionary under s18(e) on the basis that it “does not exist.”

However:
• Oracle financial systems require definitional metadata for all fields.
• MFP (which you confirm is also used) similarly requires schema documentation.
• Treasury Instructions require government agencies to maintain operational data dictionaries.
• ACC’s annual financial reporting requires structured field definitions for audit and assurance.

A statement that none of these materials exist at all appears inconsistent with the minimum governance requirements for public entities operating ERP systems.

Please confirm whether:
1. ACC interprets “data dictionary” narrowly as only the one produced for GOV-044064,
or
2. ACC is asserting that no field-definition, metadata set, schema documentation, or internal definitional material exists anywhere within Finance, Data & Analytics, or Technology Services.

This distinction is important for the accurate application of s18(e).

3. Inability to distinguish ICRA and FairWay within analysis code 06030

Your response states that:

“There are no sub-codes, attributes, or fields used to distinguish ICRA from FairWay.”

Yet ACC routinely publishes separate:
• ICRA volumes
• FairWay volumes
• Resolution times
• Decline rates
• Success/overturn statistics

and ACC released separate expenditure totals under OIA (#GOV-044064).

It would assist transparency to explain:
• The internal process or classification method used to produce these segmented totals if no coding or metadata exists;
• Whether this segmentation occurs outside the ERP (e.g., manual collation, data-warehouse views, PowerBI models, MFP tagging, etc.).

This clarification is essential to ensure the s18(e) refusal has been applied correctly.

4. Declining a clarification question under s12(2)

My Part 5 question asked:

“Can the structural metadata be supplied without invoking s18(f)?”

This was not a request for information, but a clarification designed to allow you to meet your obligations under s13: duty to assist.

Using s12(2) to decline a clarification question is unusual and appears inconsistent with Ombudsman guidance, which states that agencies should actively help requesters refine their questions before relying on refusal grounds.

I therefore respectfully request that ACC:
• Either state whether structural metadata can be provided without substantial collation (s18(f)),
• Or advise what refinement would allow the release of that information.

5. Request for reconsideration / further clarification

Given the issues outlined above, could ACC please:

A. Reconsider the application of s18(e)

in light of the publicly demonstrated existence of segmented ICRA/FairWay reporting and the standard operational metadata required for Oracle/MFP systems.

or

B. Provide a brief explanation of how ACC internally produces separate ICRA and FairWay expenditure and performance reporting

if no codes, attributes, or metadata exist in the financial systems.

This clarification is needed so the public can understand the basis for expenditure reporting and so the OIA can continue on a proper footing.

6. Acknowledgement of polite and constructive engagement

I appreciate the professionalism and timeliness of the responses received to date.
My questions are raised respectfully and in good faith, in the interests of ensuring the OIA process is accurate, transparent, and consistent with obligations under:
• s4 (purpose of the Act),
• s13 (duty to assist),
• s14 (transfer obligations), and
• s18(e)/(f) (proper application of refusal grounds).

I look forward to your clarification.

Kind regards,
Spencer Jones