Kia ora koutou,

This is a new, significantly refined request following ACC’s refusal of my earlier bundled requests (GOV-043640, GOV-043638, GOV-043667, GOV-043669 and GOV-043772) under s 18(f) of the Official Information Act 1982 on 29 October 2025 on the grounds of substantial collation and research.

I have removed all requests for individual invoices, matter references, claim numbers, per-supplier breakdowns, top-20 lists, panel arrangements, policies, correspondence, or any per-claim data. I now seek only high-level aggregated financial information that I believe is either already held in existing management reports or can be produced by a simple query of ACC’s finance/ERP system using the relevant General Ledger (GL) codes for external legal services.

Specifically, I request:

1. For each of the financial years 2020/21, 2021/22, 2022/23, 2023/24 and 2024/25 (or the nearest equivalent reporting periods used by ACC):
a. The total amount paid by ACC to external law firms and barristers for representation or advice in claimant-initiated reviews and appeals under Part 5 of the Accident Compensation Act 2001 (including ICRA, Fairway Resolution, District Court, High Court and higher appeals) – fees + disbursements + GST.
b. If readily available from existing reports, the above total broken down by forum (e.g., ICRA/Fairway reviews vs District Court appeals vs High Court and above).

2. A list of the GL account codes (and descriptions) that ACC uses to record the expenditure in (1) above. (Previous ACC OIA responses and annual reports confirm that external legal costs are captured under identifiable “consulting and professional services” or specific legal GL categories.)

I am happy to receive the information in a simple table (Excel, CSV or PDF). No individual invoices, supplier names, or cost-centre details are required.

Why this information is readily available and should not require substantial collation or research
- ACC’s Annual Reports (e.g., 2023/24: p 112–114; 2024/25 draft notes) separately report “consulting and professional services” expenditure (approximately $662 million in claims-handling costs in 2023/24 alone) and ACC has previously confirmed that external legal costs for disputes/reviews are coded to specific GL accounts.
- ACC routinely provides aggregated financial data to the Minister, Treasury, and the Auditor-General, and produces internal management reports on dispute-related legal spend for budgetary and performance monitoring purposes.
- The Ombudsman has repeatedly held that high-level aggregated financial data held in ERP/finance systems is not subject to s 18(f) when it can be extracted by standard queries (see, for example, Ombudsman case notes on similar finance-system extracts from other agencies).
- ACC has released similar aggregated legal-spend data in previous OIAs and parliamentary questions without claiming substantial collation (e.g., total litigation costs in annual reports and responses to PQ 2023–2025 on appeal success rates).

Public interest
There is strong and ongoing public interest in transparency around how much levy-payer money ACC spends on external lawyers to oppose injured New Zealanders in the statutory review and appeal process, particularly when most claimants remain self-represented and face significant barriers to justice (as noted in recent RNZ/Newsroom reporting on ICRA and Fairway processes, and in MBIE’s 2024–2025 review of review-costs regulations).

I am happy to discuss further narrowing if required, or to receive partial/rolling release.

Kind regards,
Spencer Jones