
Aku mihi,
James
James Ting-Edwards (he/him)
Senior Policy Advisor | Kaitohutohu Tuakana Kaupapahere
Office of the Privacy Commissioner | Te Mana Mātāpono Matatapu
PO Box 10094, Wellington 6140
T +64 9 302 8680 DDI s 9(2)(a)
E [email address]
privacy.org.nz
1982
From: Sarah Godwin <[email address]>
Sent: Friday, 9 May 2025 2:59 pm
ACT
To: James Ting-Edwards <[email address]>
Cc: Bonnie Hayvice <[email address]>; Katrina Quickenden <[email address]>;
Phoebe Moir <[email address]>
Subject: FW: OPC comments RE: Cabinet paper for departmental consultation - Regulatory Systems (Transport)
Amendment Bill - strengthening the efficiency of the transport system
Kia ora James,
I have taken over from Bonnie leading the Regulatory Systems (Transport) Amendment Bill (RSTA Bill).
Thanks again for your previous comments on the digital modernisation proposals in this Bill.
I am currently in the process of drafting the Cabinet paper that will introduce the Bill. I thought it
would be good to test the privacy section with you, ahead of Departmental consultation so that
INFORMATION
OPC’s views are represented accurately.
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Draft text:
1. The Bill makes legislative changes to enable digital driver licences and labels in the future.
When implemented, proposals to digitise licences and labels would change the means in
which information is collected, used and handled, raising potential privacy risks.
2. The Ministry of Transport consulted the O ice of the Privacy Commissioner (OPC) throughout
the development of the digital modernisation proposals, enabled by the Bill.
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3. The OPC is satisfied at the level of privacy analysis at this stage and encourages the Ministry,
NZTA and Department of Internal A airs will continue to work through these risks and
mitigations[1]. This will support the Minister of Transport to return to Cabinet later this year with
more detail on service design and delivery options, timeframes, and associated costs.
4. We have not identified any issues with the Bill itself complying with the principles and
guidelines in the Privacy Act 2020, though compliance will need to continue to be considered
during implementation of the digitisation proposals.
2

[1] For example, aligning digital driver licenses with the Digital Identity Services Trust Framework to
ensure standards (such as privacy) are met, to give New Zealanders confidence that their digital ID
can be safely and securely used.
Could you please let me know if you have any comments by midday Monday 12 May?
Happy to discuss if you have any questions
Thanks James,
Sarah Godwin (she/her)
Kaitohutohu Matua I Senior Policy Advisor – Regulatory Reform
Te Manatū Waka Ministry of Transport
M:s 9(2)(a)
E: [email address] | transport.govt.nz
ACT 1982
From: James Ting-Edwards <[email address]>
Sent: Monday, 17 March 2025 2:12 pm
To: Bonnie Hayvice <[email address]>
Subject: RE: OPC comments RE: Cabinet paper for departmental consultation - Regulatory Systems (Transport)
Amendment Bill - strengthening the efficiency of the transport system
Thanks Bonnie!
We don’t always get an update on how these things develop after our feedback
I’m sure if OPC will have anything more to say, but once again I’m grateful for your help providing info and
responding to my questions – very much appreciated!
Aku mihi,
INFORMATION
James
RELEASED UNDER THE
From: Bonnie Hayvice <[email address]>
Sent: Monday, 17 March 2025 2:09 pm
To: James Ting-Edwards <[email address]>
Cc: Katrina Quickenden <[email address]>; Jacob Ennis <[email address]>; Declan Lynch
<[email address]>; Katrine Evans <[email address]>
Subject: RE: OPC comments RE: Cabinet paper for departmental consultation - Regulatory Systems (Transport)
OFFICIAL
Amendment Bill - strengthening the efficiency of the transport system
Kia ora James,
Thank you for your comments. You raise some important points for us an NZTA to consider as we
determine how best to operationalise the proposals. In response to your points on proposals 1 and 2:
Comments on proposal 1: There are provisions in transport legislation that either explicitly or by
implication limit their reference to physical documentation. Enabling provisions would extend these
3
to be neutral on the form of licences/labels, where appropriate. A number of amendments across
legislation will be required to achieve this. We have not been prescriptive in the Cabinet paper as to
not limit us should we find further amendments are required.
Comments on proposal 2: I have strengthened the privacy assessment section to clarify that there
are potential privacy risks and mitigations associated with mandating the collection and provision of
electronic addresses, see below:
NZTA assesses the impact of this proposal as ‘medium’. Mandating the collection and provision of
electronic addresses raises potential privacy risks such as potential reliance on inaccurate
information (e.g., if email addresses are not kept up to date) and could further expose New
Zealanders to cybersecurity risks, scams and phishing. However, NZTA considers these risks can be
satisfactorily mitigated by applying similar safeguards as for other personal information they hold.
NZTA also assesses that the proposal will reduce risks as e-servicing will enable emails and
attachments to both be password-protected to enhance privacy. This has fewer privacy risks than the
current practice of posting such notices to physical addresses, with no confirmation of receipt, and in
envelopes that can be opened by anyone.
Thanks again,
Bonnie
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From: James Ting-Edwards <[email address]>
Sent: Friday, 14 March 2025 11:25 am
To: Bonnie Hayvice <[email address]>
Cc: Katrina Quickenden <[email address]>; Jacob Ennis <[email address]>; Declan Lynch
<[email address]>; Katrine Evans <[email address]>
Subject: OPC comments RE: Cabinet paper for departmental consultation - Regulatory Systems (Transport)
Amendment Bill - strengthening the efficiency of the transport system
Kia Ora Bonnie,
Thank you for the opportunity to comment on this Cabinet paper, and for the very helpful engagement to
understand the policy intent and the scope of work involved – our comments follow.
We have said in previous comments that proactive work on privacy, inclu
INFORMATION ding learning privacy and
cybersecurity lessons from other jurisdictions, is critical for work on a digital driver licence to uphold
New Zealanders’ trust and operate as intended. We are pleased to see substantial consideration of
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privacy issues in this Cabinet paper.
We are also grateful to MoT and NZTA for sharing the brief NZTA analysis of privacy issues. This
has helped us understand the issues and formulate comments. As the Cabinet paper discusses,
further work on privacy will be needed, but even a brief analysis early on can help to inform the
people doing the work as well as decisionmakers.
OFFICIAL
We are supportive of moves to enable well-considered use of digital technologies. Our comments
below address some points of detail about the process here, but very much from a perspective on
“how to” rather than “don’t do”.
Proposal 1: Form of driver licence
The Cabinet paper refers to legislative steps to enable the adoption of a digital driver licence, but
does not specify what law changes are in scope for this phase of work. We suggest the paper could
be clearer on this point.
4
From conversations with MoT, we understand the policy intent for this phase of work is to remove
technical legal barriers to adoption of a digital driver licence as an initial step, but that the actual
adoption of any digital driver licence solution would depend on further policy work, privacy analysis,
and Cabinet approvals which OPC would have the chance to engage on.
An example of the kind of change we understand to be in scope at this stage is an amendment to s
28(1) of the Land Transport Act 1998 which provides “a driver licence must be in the prescribed
form and must have on it …”, to remove the legal requirement implied by the word “on” that a
licence be in a physical form.
On the basis that relevant law changes in scope for approval here are minor and technical, and that
there will be further Cabinet approvals and opportunities for us to engage through the development
of any digital driver licence, we see the privacy risks presented at this stage as relatively minor and
as not presenting a barrier to this work advancing.
We are also encouraged to see that the brief privacy impact analysis discusses privacy issues and
mitigations, with reference to experiences from Australia, the ISO standard, and alignment with the
Digital Identity Trust Framework. We particularly note the references to potential enhancements to
privacy from avoiding the physical handover of cards or devices, and the potential to disclose less
information than a physical driver licence reveals.
We do think it would be helpful to be more explicit in the Cabinet paper about what legal changes
are in scope for this phase of work. We have relied on (and appreciate) conversations with MoT to
understand the policy intention here, but decision-makers and consulted stakeholders need a clear
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understanding of what changes are being proposed at this time.
Electronic issuing of fees and notices – mandatory collection/provision of email addresses
We understand the policy intention behind the proposal to mandate collection/provision of email
addresses is to enable electronic service of regulatory notices, including for fees and infringements,
by ensuring there is an email address to send them to.
We are not opposed to this approach, but think Proposal 2 would benefit from further analysis of
privacy risks and mitigations. This work would help to ensure that decisions here are fully informed
on privacy, and could be added to NZTA’s brief privacy analysis.
We understand efficiency and modernisation arguments for moving to digital communication
methods. Our concern is the proposal to mandate collection of email addresses as opposed to
INFORMATION
allowing individuals to opt in on an informed voluntary basis. When a policy proposal involves an
intrusion on New Zealanders’ privacy, we are looking to see a strong policy case (including analysis
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of privacy risks and mitigations) showing that the intrusion on privacy is in proportion to the benefits
for individuals and for society.
Moving from voluntary to mandated collection and provision of an email address involves an
intrusion on New Zealanders’ privacy and also contributes to other potential privacy risks. As
illustrative examples, some of those privacy risks relate to:
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o Accuracy: for a range of reasons, not least established barriers to full digital inclusion in
New Zealand, not everyone maintains an active email account which they alone control and
check regularly. Mandating that people provide a contact email creates a risk that people will
provide an old, or shared, or irregularly checked email address. This creates risks of NZTA
relying on inaccurate information about people, people missing infringement notices, and
potential for catch-22 situations if email is relied upon to correct issues with email.
o Data breaches and email security: Mandated use of email for NZTA notices may increase
New Zealanders’ exposure to privacy and cybersecurity risks. Poor email hygiene (sending
email to the wrong address, including bulk emails to wrong recipients) remains one of the
leading causes of data breaches in New Zealand. Email providers and email recipients are
5

also open to phishing and other cybersecurity attacks. Shared email accounts (eg accounts
for a household) create a risk of inappropriate disclosure to third parties.
o Scams and phishing: requiring an electronic point of contact for NZTA may escalate the
risk New Zealanders face from inauthentic messages: scams, spam, and phishing. You may
wish to consider how NZTA will build understanding and trust of email communications if
this is to be a primary contact method.
We agree with the Cabinet paper at [45] and the brief privacy impact analysis at 1.1(b) that in some
situations electronic mail may enhance privacy compared with physical mail. We think adding
discussion of potential privacy risks and mitigations to the work already done would help to ensure
the coverage of privacy issues is balanced and support informed decisions on Proposal 2.
Finally, as a background consideration, digital services can be complicated and hard for some New
Zealanders to use and trust. In this context, as with digital driver licences, it may also be worth
considering whether all New Zealanders are ready for a shift to electronic service of notices.
Retaining physical and non-digital options may be important to maintain trust with some key
demographics and to support their preferred approach to providing and accessing their personal
information. You might consider this in any further analysis.
Aku mihi,
James
ACT 1982
James Ting-Edwards (he/him)
Senior Policy Advisor | Kaitohutohu Tuakana Kaupapahere
Office of the Privacy Commissioner | Te Mana Mātāpono Matatapu
PO Box 10094, Wellington 6140
T +64 9 302 8680 DDI s 9(2)(a)
E [email address]
privacy.org.nz
INFORMATION
RELEASED UNDER THE
From: Bonnie Hayvice <[email address]>
Sent: Thursday, 6 March 2025 9:38 am
To: "Monica Rogers" <[email address]>; "Rachel Townrow" <[email address]>; "Ben
Temple" <[email address]>; "Linda Cameron" <[email address]>; "Gwen
Rashbrooke" <[email address]>; James Ting-Edwards <[email address]>;
leavers <[email address]>; Ewan Lincoln <[email address]>; "Olivia Maxwell [TSY]"
OFFICIAL
<[email address]>; Official Correspondence NZTA <[NZTA request email]>;
"[email address]" <[email address]>; Brendan Gage [DPMC]
<[email address]>; June Ralphs <[email address]>; [email address];
[email address]; [email address]; Hayden Glass <[email address]>; Steve
Penman <[email address]>; Amanda Richards <[email address]>
Cc: Katrina Quickenden <[email address]>; Jacob Ennis <[email address]>; Declan Lynch
<[email address]>
Subject: RE: Cabinet paper for departmental consultation - Regulatory Systems (Transport) Amendment Bill -
strengthening the efficiency of the transport system
6
Kia ora koutou,
Please note the extended timeframe for your feedback now due COP Friday 14 March. This reflects a
delay in the commencement of ministerial consultation, and as a result, the intention for the paper to
now be considered by ECO on 26 March.
Cheers
Bonnie
Duplication of email dated 5 March 2025 from Bonnie H
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INFORMATION
RELEASED UNDER THE
OFFICIAL
Document 13
Neha Pawar
From:
James Little <[email address]>
Sent:
Thursday, 15 May 2025 4:04 pm
To:
Laura Bender
Cc:
Katrina Quickenden; [email address]; [email address];
[email address]
Subject:
RE: Departmental consultation: Cabinet paper on Land Transport Rules
Reform Programme
Follow Up Flag:
Follow up
Flag Status:
Completed
Kia ora Laura,
Thank you for the opportunity to provide feedback on the attached draft Cabinet paper.
From the perspective of the Digital Identity team within the Department of Internal A airs we are highly
supportive of the proposed workstream to enable a digital driver licence. As you are aware, we are working very
closely with NZTA on the practical implementation of this, and its role in the wider NZ digital identity
ecosystem.
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Our key concern however is on the timing. We would strongly support workstream 5 “Enabling a digital driver
licence, digital documents, and e-servicing” being progressed quicker than is proposed. We suggest this
workstream should be brought forward to align with workstreams 2, 3, and 4a with consultation beginning in
October 2025 and rules changes by May 2026. s 9(2)(g)(i)
Bringing this workstream forward would ensure the maximum amount of certainty for the wider public and
private sector to invest in the infrastructure necessary to allow for them to receive/verify a digital driver licence
and will ensure alignment with a best-case scenario for NZTA’s development of a digital driver licence.
Happy to discuss this further, don’t hesitate to reach out.
James Little | Market Development Lead INFORMATION
Digital Identity Services Trust Framework Group
Te Tari Taiwhenua | Department of Internal A airs
RELEASED UNDER THE
s 9(2)(a)
From: Laura Bender <[email address]>
Sent: Wednesday, 7 May 2025 3:47 pm
To: [email address]; Official Correspondence NZTA <[NZTA request email]>; Steve
Penman <[email address]>; James Little <[email address]>; [email address];
[email address]; el ie.argyle@just
OFFICIAL ice.govt.nz; [email address]
Cc: Katrina Quickenden <[email address]>
Subject: Departmental consultation: Cabinet paper on Land Transport Rules Reform Programme
You don't often get email from [email address]. Learn why this is important
Tēnā koutou,
1

Please find attached a draft Cabinet paper on the Minister of Transport’s Land Transport Rules
Reform Programme, for departmental consultation. Please provide any feedback by the end of
Wednesday 21 May. Ministerial consultation is set to occur in parallel.
The draft paper seeks Cabinet’s agreement to:
The Minister’s programme of work to reform land transport rules
Give the Minister of Transport authority to approve documents for public consultation on most
of the workstreams, in line with policy direction signalled in the paper.
The intention is for the paper to be discussed at ECO on 4 June.
Please note that, since the paper was drafted, the Minister of Transport has delegated a further
workstream to the Associate Minister (reviewing light vehicle warrant of fitness and certificate of
fitness frequency and inspection requirements). Future versions of the paper will be updated to
signal that the Associate Minister will return to Cabinet to seek agreement for any consultation in that
workstream, rather than seeking authority for the Minister to approve consultation documents.
Let me know if you have any questions. If you’re not the right person in your organisation to provide
comment, please let me know so that I can send it to whoever is best placed to do so.
Ngā mihi,
ACT 1982
Laura
Laura Bender (she/her)
Kaitohutohu Mātāmua I Principal Adviser
Kaupapahere mō ngā take Whakarite I Regulatory Reform
Te Manatū Waka Ministry of Transport
M: s 9(2)(a)
| E: [email address] | transport.govt.nz
INFORMATION
MINISTRY OF TRANSPORT
RELEASED UNDER THE
Wellington (Head Office) | Ground Floor, 3 Queens Wharf | PO Box 3175 | Wellington 6011 | NEW ZEALAND | Tel:
+64 4 439 9000 |
Auckland | NZ Government Auckland Policy Office |Level 7, 167B Victoria Street West | PO Box 106238 | Auckland
City | Auckland 1143 | NEW ZEALAND | Tel: +64 4 439 9000 |
Disclaimer: This email is only intended to be read by the named recipient. It may contain information which is
confidential, proprietary or the subject of legal privilege. If you are not the intended recipient you must delete this
OFFICIAL
email and may not use any information contained in it. Legal privilege is not waived because you have read this email.
Please consider the environment before printing this email.
2
Document 14
Neha Pawar
From:
Steve Penman <[email address]>
Sent:
Wednesday, 21 May 2025 12:54 pm
To:
Laura Bender
Cc:
Amy Moorhead; Official Correspondence NZTA
Subject:
FW: Departmental consultation: Cabinet paper on Land Transport Rules
Reform Programme
Attachments:
OC250315 Land Transport Rules Reform Programme - Cabinet Paper (1) (002).docx
Kia ora Laura
Thank you for seeking NZTA feedback on the Departmental consulta on version of the Cabinet paper on the Land
Transport Rules Reform Programme. Please find a ached our feedback in the form of comments and suggested
track changes.
We note that the Recommenda ons sec on is yet to be finalised. We would appreciate the opportunity to provide
further feedback on the final dra Recs once these are prepared.
Happy to discuss.
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Thank you.
Ngā mihi
Steve Penman
Lead Advisor System Policy
Te Tūāpae – System Leadership
Email: [email address]
Phone: s 9(2)(a)
Mobile:
NZ Transport Agency Waka Kotahi
INFORMATION
44 Bowen Street
Private Bag 6995, Wellington 6141, New Zealand
RELEASED UNDER THE
Duplication of email dated 7 May 2025 from Laura B
OFFICIAL
1
I N C O N F I D E N C E
4. Simplifying heavy vehicle driver licencing, weight thresholds, and freight
permitting
5. Enabling a digital driver licence, digital documents, and e-servicing
6. Improving lane use and use of traffic control devices, and minor system
improvements
7. Overhauling the vehicle regulatory system.
5
Consultation has already occurred on Workstream 1 (vintage and motorhome
WOFs/COFs). For Workstream 2 (Considering additional safety requirements) the
Associate Minister of Transport will bring any proposals for public consultation to
Cabinet for agreement.
6
To enable the remaining rule reforms to progress efficiently, I seek delegation from
Cabinet for the Minister of Transport to approve the consultation materials for the
remaining changes as they are drafted over the next 18 months (rather than returning
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to Cabinet for approval each time). They would need to be broadly consistent with the
policy direction set out in this paper. If, following consultation, I intend to make
changes that are significant or controversial, I will bring those proposals to Cabinet
for agreement.
Background
7
The Government Policy Statement on land transport (GPS) includes a commitment to
review the vehicle regulatory system to enable better management of the safety
performance of the vehicle fleet, reduce regulatory burden, and ensure our domestic
rules are fit for purpose.
8
In the current land transport regulatory system, updating rules and other system
settings is time consuming and complex. This leads to a system that is slow to adapt to
changing technology, a substantial administrative burden to keep rules up to date or
operate under out-of-date rules, and frustration and uncertainty among stakeholders.
INFORMATION
9
To address this, I have developed a work programme with the following objectives:
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•
Improve consumer choice in the vehicle market: for example, through reducing
unnecessary vehicle import requirements
•
Reduce regulatory compliance costs: for example, by removing unnecessary
WOF and COF inspections and increasing inspection effectiveness/efficiency
•
Digitise and modernise government services: for example, enabling digital
alternatives to stickers for WOF/COF inspections and a digital driver licence
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•
Increase freight productivity: for example, by enabling larger trucks on certain
routes without needing to seek permits
2
I N C O N F I D E N C E
I N C O N F I D E N C E
•
Improve the safety and quality of our vehicle fleet over time: for example, by
considering mandating certain safety features in new vehicle imports.
10
The work programme has been informed by engagement by the Ministry of Transport
and NZTA with a range of vehicle sector stakeholders to better understand the
transport sector’s concerns and priorities for reform. Stakeholder feedback on the
programme so far has been broadly supportive.
11
Annex One maps my objectives and workstreams to existing problems and
opportunities.
I seek agreement to progress five workstreams to possible public consultation
12
The Minister of Transport may amend rules, generally following public consultation. I
seek delegation of authority to approve consultation material on Workstreams 3-7.
This is on the basis that:
• Most of the topics have general support or are uncontentious (with exceptions
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noted in the section below on Workstream 3 – paragraph 17)
• This paper outlines the general policy direction of this work for Cabinet’s
consideration
• Regulatory impact analysis requirements will be met for each workstream.
13
If, following consultation, I intend to make changes that are significant or
controversial, I will bring those proposals to Cabinet for further discussion.
14
Consultation has already occurred on reducing the frequency of vintage/veteran and
privately-owned heavy motorhome WOF and COF inspections (Workstream 1), with
98% of submitters supporting the changes for vintage/veteran vehicles and 89%
supporting the proposals for privately-owned heavy motorhomes. I expect further
advice on the rule change in June 2025.
15
I have delegated the workstream on considering additional safety requirements
INFORMATION
(Workstream 2) to the Associate Minister of Transport, who will bring any proposals
for public consultation to Cabinet for your agreement.
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16
The sections below outline the high-level policy direction for each of the remaining
workstreams (3-7). A more detailed table of the scope and timeframes for each
workstream is included in
Annex Two.
Workstream 3: Reviewing WOF/COF frequency and inspection requirements for light
vehicles
Out of Scope
OFFICIAL
17
New Zealand’s vehicle inspection system is not as effectively targeted to risk as it
could be. We check some things too often and other high-risk issues insufficiently or
not at all. New Zealand has one of the most rigorous frequent inspection programmes
3
I N C O N F I D E N C E
I N C O N F I D E N C E
in the world, and it is not clear if this is delivering sufficient safety benefits to justify
the costs imposed. Reviewing inspection frequency while improving testing could
make the system more fit-for-purpose and lower some compliance costs.
18
Building on the strong support for reducing WOF/COF frequency for vintage/veteran
vehicles and privately-owned heavy motorhomes, it is timely to review the WOF/COF
settings for all other light vehicles. This includes personal cars and motorbikes as well
as light commercial vehicles like taxis and rental cars.
19
Any proposal to reduce WOF/COF frequency is likely to be contentious with the
vehicle inspection industry, and other stakeholders concerned about safety, as was
experienced during consultation on the current requirements (set in 2014). Subsequent
NZTA monitoring of the previous changes has shown a small but statistically
Out of Scope
significant increase in deaths and serious injuries where vehicle faults were recorded
as a contributing factor.
20
This previous experience highlights that the key will be striking a balance between
reducing cost and inconvenience for vehicle owners and ensuring while maintaining
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or improving vehicle related road safety outcomes. It may also be possible to
somewhat mitigate the risk of negative effects on safety by improving the
effectiveness of inspections and better targeting them to risk.
Workstream 4: Simplifying heavy vehicle driver licencing, weight thresholds, and freight
permitting
21
I aim to remove unnecessary heavy vehicle driver licence classes, reduce wait times
and make it easier for commercial drivers to progress through licensing classes, as
well as simplify and remove some technical requirements.
22
This workstream also looks to enable Class 1 licence holders to drive heavier vehicles
(and tow fully laden light trailers) without requiring a Class 2 licence. This reflects
that the risk of those slightly heavier vehicles and towing combinations has been
offset by advances in vehicle technology like antilock braking systems, electronic
stability control and trailer sway control. Changes to these settings could also better
INFORMATION
enable low/zero-emission heavy vehicles.
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23
We have a prescriptive and overly burdensome approach to regulating heavy and
special vehicles. This particularly relates to the permitting of heavy trucks, which may
be able to be removed entirely. There are numerous rules that deliver little benefit to
the public and impose an unnecessary cost on the sector. This includes the need to
affix ‘H plates’ on what are now certain commonly-used heavy vehicles, which notify
the public that a vehicle exceeds a set mass and dimensions.
24
My work programme also includes a review of the Vehicle Dimension and Mass
Rule, which sets dimension and mass limits to enable vehicles, in particular, heavy
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truck and trailer combinations, to be operated safely on New Zealand’s roads.
However, the complexity of assessing the road maintenance issues associated with
greater vehicle weights and alternative configurations means that significant research
4
I N C O N F I D E N C E
I N C O N F I D E N C E
is required to understand the costs and benefits of any changes and inform policy
decisions. For this reason, I do not anticipate public consultation within the 18-month
timeframe that is the focus of this paper.
Workstream 5: Enabling a digital driver licence, digital documents, and e-servicing
25
Too much of our transport regulatory system relies on physical mail, stickers,
licences, and other paperwork. This is unnecessary, inconvenient for the public, and a
significant cost to businesses. I have heard from some companies that they receive up
to 150 letters a day from government, with each one needing to be physically signed,
witnessed, and sent back. Over the year to March 2025, NZTA sent out 14 million
Commented [WT3]: Suggest add at end: “Over the
letters, reminders and labels at a cost of $16.8 million including printing costs.
year to March 2025, NZTA sent out 14 mil ion letters,
reminders and labels at a cost of $16.8 mil ion including
printing costs.”
26
The Associate Minister of Transport is already progressing primary legislative change
to enable a digital driver licence, greater use of digital documents and better e-
servicing (CAB-25-MIN-0086 refers). In tandem, I will progress changes to rules and
regulations to enable greater modernisation of these government services.
Commented [WT4]: Would it be more accurate for the
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paper to say (instead of “in tandem.. ”) “A number of the
27
These changes are likely to receive widespread support from the public and sector
rule/regulation changes that I am now proposing wil
help give effect to these legislative changes” or similar?
stakeholders.
Commented [SP5R4]: Yes, but 'in tandem' is also fine,
the rule changes and primary legislation are best
Workstream 6: Improving lane use and use of traffic control devices, and minor system
thought of as a package. The rules/regulation changes
are not necessarily consequential to the primary
improvements
legislation.
28
The previous government consulted on various changes to path and lane use. We are
Out of Scope
supportive of progressing and potentially consulting on a small number of these
proposals, including:
• Enabling e-scooters to be ridden in bike lanes (currently they can only legally be
ridden on footpaths and roads)
• Enabling children to ride bicycles on footpaths, which can have positive safety
outcomes
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• Requiring drivers to give way to buses exiting bus stops.
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29
There is also a range of minor options being explored by the Ministry of Transport
and NZTA to improve the way our transport system operates. This includes
improvements to regulating traffic control devices (e.g. road signs and markings).
Workstream 7: Overhauling the vehicle regulatory system
30
There is a longer-term piece of work to overhaul the regulatory system, with a
particular focus on entry requirements. New Zealand is a taker of vehicles and vehicle
technology with limited influence over the vehicle manufacturing market. We
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generally seek to align our regulation with other jurisdictions. However, our
5
I N C O N F I D E N C E
I N C O N F I D E N C E
regulations rules and requirements have not kept up with changes in the international
automotive industry, and are overly prescriptive and slow to update.
31
We will look to reduce complexity by considering how to harmonise our regulations
with other jurisdictions, for example by using the same paperworkadopting the same
Out of Scope
requirements and processes as they do (e.g. type approval). This could have a large
impact over time by reducing compliance costs and making it easier to import new
vehicle types. This could improve consumer choice and freight productivity.
32
This is a longer-term programme than the other workstreams listed here, but I plan to
consult on broad options in May 2026.
Implementation
33
This paper proposes staged consultation on a range of possible regulatory changes.
The implementation timeframes for the possible changes will be determined following
public consultation. Some of the changes may require substantial implementation
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programmes, system changes, and associated funding decisions, which I would
discuss with Cabinet when seeking agreement to final proposals.
Cost-of-living Implications
34
Any cost-of-living implications of the various possible changes will be considered
through the regulatory impact assessment process.
Financial Implications
35
Any financial implications of the various possible changes will be considered through
the regulatory impact assessment process and as part of final decisions on progressing
any changes to rules.
Legislative Implications
36
Each of the proposals will require amendments to land transport rules (secondary
INFORMATION
legislation). There may also be amendments to land transport regulations if new
offences and penalties are required. The legislative implications of the workstream on
RELEASED UNDER THE
overhauling the vehicle regulatory system will depend on the scope and approach for
that work, which are still being developed.
37
While the main focus is on rules changes, it is possible that the work programme will
eventually also lead to changes to primary legislation that would bind the
Crow
n.https://dpmc.govt.nz/publications/co-02-4-acts-binding-crown-procedures-
cabinet-decision
OFFICIAL
6
I N C O N F I D E N C E
I N C O N F I D E N C E
Impact Analysis
Regulatory Impact Statement
38
The proposals will require regulatory impact analysis or exemptions prior to
consultation. This analysis will be provided to me prior to the approval of consultation
documents, anddocuments and must meet or partially meet requirements for
consultation to proceed. This proposed approach has been agreed with the Ministry
for Regulation.
Climate Implications of Policy Assessment
39
Any climate change implications of the various possible changes will be considered
through the regulatory impact assessment process.
Population Implications
40
Any population implications of the various possible changes will be considered
ACT 1982
through the regulatory impact assessment process.
Human Rights
41
Any human rights implications of the various possible changes will be considered
through the regulatory impact assessment process.
Use of external Resources
42
No external resources were used in policy development of the proposals.
Consultation
43
The Ministry of Transport and NZTA sought input from a range of stakeholder
groups, and received general support for the work programme from the following:
INFORMATION
• National Road Carriers Association (NRC)
• Heavy Haulage Association
RELEASED UNDER THE
• Imported Motor Vehicle Association (VIA)
• Ia Ara Transporting New Zealand (TNZ).
Out of Scope
44
TNZ and the Heavy Haulage Association also provided detailed feedback about the
scope and timing of specific work programme items.
45
[To update following departmental consulta
OFFICIAL tion]
7
I N C O N F I D E N C E
I N C O N F I D E N C E
Communications
46
I will announce the high-level programme of work in a press release in June 2025.
Proactive Release
47
I will proactively release this paper within the standard 30-day period following
Cabinet Decisions.
Recommendations
The Minister of Transport recommends that the Committee:
48
agree to the direction for the land transport rules reform programme laid out in this
paper.
49
note that consultation has already occurred on reducing the frequency of
vintage/veteran and privately-owned heavy motorhome Warrant of Fitness and
ACT 1982
Certificate of Fitness inspections.
50
note that the Associate Minister of Transport will bring any proposals for public
consultation on additional safety requirements for imported vehicles to Cabinet for
your agreement.
51
authorise the Minister of Transport to approve, provided they are broadly consistent
with the policy direction set out in this paper and its annexes, materials for public
consultation on:
51.1 Reviewing Warrant of Fitness and Certificate of Fitness frequency and
inspection requirements for light vehicles (other than vintage/veteran
vehicles);
51.2 Simplifying heavy vehicle driver licencing, weight thresholds, and freight
Out of Scope
permitting, including:
INFORMATION
51.3 Enabling the use of digital driver licences, digital documents, and e-servicing
(in line with changes agreed by Cabinet in CAB-25-MIN-0086);
RELEASED UNDER THE
51.4 Improving lane use and use of traffic control devices, and minor system
improvements (previously consulted on as per DEV-19-MIN-0097); and
51.5 Overhauling the vehicle regulatory system.
Once the Minister has approved the draft Cabinet paper for lodgement for Cabinet or a
Cabinet committee, this section should be updated
OFFICIAL to state ‘Authorised for lodgement’.
8
I N C O N F I D E N C E
I N C O N F I D E N C E
Hon Chris Bishop
Minister of Transport
ACT 1982
INFORMATION
RELEASED UNDER THE
OFFICIAL
9
I N C O N F I D E N C E
I N C O N F I D E N C E
Annex One – Land transport regulatory system problems, objectives and workstreams
Commented [AC11]: Suggestions:
Typo in top second bubble - ‘Unnecessary’
Suggest replacement of ‘freight’ with ‘heavy vehicle’ to
capture buses and agricultural vehicles
Workstream box 1:
Problems and opportunities:
Objectives:
Workstreams:
suggest ‘Reducing WOF/COF frequency for
vintage/veteran and private heavy motorhomes’
1) Reducing the
3) Reviewing WOF/
6) Improving lane use
Unneccessary costs for
Reduce regulatory
frequency of vintage COF frequency and
and use of traffic
users and the sector
compliance costs
and motorhome
inspection
control devices, and
WOFs/COFs
requirements for light minor system
Regulation not always
vehicles
improvements
targeting the right things
4) Simplifying heavy
Inhibits freight
Increase freight
and special vehicle
ACT 1982
productivity
productivity
driver licencing,
weight thresholds,
and freight permitting
2) Considering further
Barriers to new and
Import req'ts falling
Improve the safety and
safety requirements
emerging technology
behind int'l standards,
quality of our vehicle
for vehicle imports
(eg heavy EVs)
trade obligations
fleet
7) Overhauling the
Inhibits access to
Improve consumer
vehicle regulatory
affordable, low-
choice in the vehicle
system
emissions vehicles
market
A more adaptable and
System is old and hard to
Effort wasted managing
enabling regulatory
change
by exception
system INFORMATION
RELEASED UNDER THE
5) Enabling a digital
Services not always
driver licence, digital
easy for users to
Digitise and modernise
documents, and e-
access/use
government services
servicing
OFFICIAL
I N C O N F I D E N C E
I N C O N F I D E N C E
Annex Two – Scope and timing for each workstream
Out of Scope
The diagram below summarises each workstream and outlines the time between when consultation starts, and the rule is in placesigned for each change.
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reducing vintage/motorhome WOF/COF
2) Considering further safety requirements for imports (tentative timeframes – TBC)
3) Reviewing WOF/COF inspection requirements and frequency
4a) Freight permitting
4b) Licence weight thresholds
5) Enabling a digital driver licence, digital documents, and e-servicing
6) Improving lane use and use of traffic control devices
7)Overhauling the system
Workstream
Included in scope
Expected timeframe
1) Reducing the frequency of
• Reduce the frequency of WOF inspections for vintage/veteran light vehicles from 6 months to 1 year
Consultation is complete
veteran/vintage and motorhome WOF
• Reduce the frequency of COF inspections for private heavy motorhomes from 6 months to 1 year
Rule change signed in August 2025
and COF inspections
ACT 1982
2) Considering further safety
• Consider mandating additional safety features in vehicle imports, including possible phased introduction
Tentative timeframes (TBC): Consultation in
requirements for vehicle imports
October 2025; Rule change in May 2026
3) Reviewing WOF/COF frequency and
• Review the frequency of light vehicle WOF inspections
Consultation in October 2025
inspection requirements for other light
• Review the scope of light vehicle WOF inspections
Rule change signed in May 2026
vehicles
• Review the frequency of light passenger commercial vehicle (taxi and car rental agency) COF inspections
• Consider transitioning light commercial vehicle COF inspections to (lower-cost) WOF inspections, and other COF weight threshold issues
4) Simplifying heavy vehicle driver
• Reform permitting requirements for 50MAX trucks
(Some changes previously consulted on, per
licencing, weight thresholds, and
• Review requirement to display H plates
DEV-19-MIN-0009)
freight permitting
• Review restrictions on overweight and over-dimension vehicle movements
Consultation in October 2025 (freight
• Review and consider adjusting weight thresholds for Class 1 and Class 2 licences
permitting) and Feb 2026 (weight thresholds)
• Consider licence class adjustments where the Director of Land Transport has issued an exemption
Workstream 5:
First bullet: Suggest to make clear the physical DL is
• Improve the heavy vehicle driver licensing pathway for immigrants
Rules changes signed May 2026, June 2026
stil the primary/’always’ going to be offered, that
• Simplify heavy vehicle driver licencing, including:
Possible consultation on heavy and special
‘complementary offering’ is a more accurate description
re: the digital version.
o Simplifying the progression from Class 2-5 licences
vehicle driver licencing TBC
Second bul et suggest the text on WOF/COF rego
o Reviewing the Accelerated Licensing Process
stickers is extended to include the removal of
o Reviewing the requirements for special-type vehicle endorsements
requirement for their display.
Out of Scope
o Standardising speed thresholds for tractors and special-type vehicles
o Simplifying the rules for tractors that can be driven on a Class 1 licence
o Considering automatic renewal of general licences for some endorsement holders.
5) Enabling a digital driver licence,
• Enable a digital driver licence as an alternative toin addition to a physical licence
Consultation in February 2026
digital documents, and e-servicing
• Enable digital alternatives to WOF/COF/Rego stickers to be tied to licence plate recognition
Rule change signed in June 2026
INFORMATION
• Better enable NZTA to col ect, store, and electronically transmit regulatory notices
Commented [EC14]: If NZTA implements the
• Enable online theory tests and digital temporary licences
Austroads digital driver licence solution, physical driver
• Simplify identification requirements for NZTA customers
licence cards wil continue to be issued to customers
and it's likely most customers wil need to use the
RELEASED UNDER THE
6) Improving lane use and use of traffic
• Enable e-scooters to use cycle lanes and children to ride bikes on footpaths
(Some changes previously consulted on. per
physical card during the identity proofing process for a
control devices, and minor system
• Minimum overtaking gap for passing cyclists, horse riders, etc.
DEV-19-MIN-0097)
DDL. Although the intention is that customers wil be
improvements
• Require vehicles to give way to busses exiting bus stops
able to use their DDL for the same purposes as the
Consultation in February 2026
physical card, the DDL wil be complimentary to the
• Various updates to traffic control devices and minor/technical changes
physical card (ie not issued as a stand alone document)
Rule change signed in June 2026
7) Overhauling the vehicle regulatory
• Simplify and refocus import requirements e.g. automatic recognition of overseas standards
Consultation on options in May 2026
system
• Explore adoption of type approval
Rule change sigining TBC in 2027
• Systematic review and overhaul of the vehicle regulatory system to make it more adaptable, e.g. to new technologies
Note the proposed consultation would be on initial, high-level options, rather than a specific proposal and draft rule
OFFICIAL
I N C O N F I D E N C E

Document 15
Neha Pawar
From:
Rachel Townrow <[email address]>
Sent:
Thursday, 29 May 2025 2:23 pm
To:
Sarah Godwin; Phoebe Moir
Cc:
Katrina Quickenden; Declan Lynch; Monica Rogers
Subject:
RE: In confidence - Departmental consultation - Regulatory Systems (Transport)
Amendment Bill and draft Cabinet paper.
Categories:
ongoing work
Kia ora Sarah
s 9(2)(h)
A practical thought on the proposal to enable digital registration and WoF documents, which you’re likely
ACT 1982
already aware of – compliance monitoring and enforcement is relatively straightforward and requires little
resource when it is simply a matter of looking at a vehicle’s windscreen to determine compliance. If additional
work is required (i.e. checking the licence plate in a database) this may increase the cost of monitoring and
enforcement which may in turn reduce the amount of this work that is carried out. Our interest in this is on the
basis of council o icers having delegated authority to monitor and enforce compliance with registration and
WoF requirements. If that authority is to continue council sta will need to be able to access the digital
information, and we’d ask that the impacts of the change on their operating model be taken into account when
considering the proposal. If that authority is not going to continue this could have an impact on resourcing for
some councils and we’d ask that this be taken into account when considering any proposal to remove that
authority. Very happy to discuss this further if that would be useful.
Ngā mihi nui
Rachel Townrow (she/her) Kaitātari Kaupapa Here Matua | Senior Policy Analyst
INFORMATION
Local Government Policy, Partnerships and Operations
Policy and Te Tiriti
RELEASED UNDER THE
Te Tari Taiwhenua | Department of Internal A airs
PO Box 805, Wellington 6140, New Zealand | www.dia.govt.nz
OFFICIAL
My usual days of work are Monday-Wednesday
From: Sarah Godwin <[email address]>
Sent: Tuesday, May 27, 2025 10:38 AM
To: James Little <[email address]>; Phoebe Moir <[email address]>
Cc: Katrina Quickenden <[email address]>; Declan Lynch <[email address]>; Shiyi
Redpath <[email address]>; Monica Rogers <[email address]>; Rachel Townrow
<[email address]>; Mike West <[email address]>
1

Subject: RE: In confidence - Departmental consultation - Regulatory Systems (Transport) Amendment Bill and draft
Cabinet paper.
You don't often get email from [email address]. Learn why this is important
Mōrena James,
Thank you for this feedback, and for providing it early – really appreciate it! good to hear there are no
major red flags from DIAs perspective.
Phoebe – please see below for DIA’s feedback on the Bill.
I can make edits to the other documents accordingly.
I’ll also send you a separate email James – we are keen to catch up on DDL more broadly and next
steps for this work.
Thanks,
Sarah Godwin (she/her)
Kaitohutohu Matua I Senior Policy Advisor – Regulatory Reform
ACT 1982
Te Manatū Waka Ministry of Transport
M: s 9(2)(a)
E: [email address] | transport.govt.nz
From: James Little <[email address]>
Sent: Tuesday, May 27, 2025 10:27 AM
To: Sarah Godwin <[email address]>
Cc: Katrina Quickenden <[email address]>; Phoebe Moir <[email address]>; Declan
Lynch <[email address]>; Shiyi Redpath <[email address]>; Monica Rogers
INFORMATION
<[email address]>; Rachel Townrow <[email address]>; Mike West
<[email address]>
RELEASED UNDER THE
Subject: RE: In confidence - Departmental consultation - Regulatory Systems (Transport) Amendment Bill and draft
Cabinet paper.
Morning Sarah
Thank you for the opportunity to provide feedback. The Department of Internal A airs, and the Trust
Framework Group, are very supportive of thi
OFFICIAL s work to progress changes to enable an electronic driver licence
through the Land Transport Act.
I’ve provided some feedback below on the current drafted amendments as well as the departmental
disclosure. It’s fair to say, they’re all small detail issues rather than substantive issues! But hopefully this will
assist and save some time at select committee.
Cabinet paper
Para 29 notes there has been no public consultation on introducing a digital driver licence. You may
wish to include a further note that it is not expected this will be contentious and that existing
engagements by NZTA and DIA on the subject have had strong support.
2
Regulatory Systems (Transport) Amendment Bill
s 9(2)(h)
ACT 1982
Departmental Disclosure Statement
There are several mentions in this document to the e ect of “when this te
INFORMATION chnology is available”.
Regarding electronic driver licences, this technology is already available and widely used abroad. I
recommend clarifying this to ensure we are not giving the impression that the te
RELEASED UNDER THE chnology necessary for
mobile driver licences isn’t already available and widely used. Instead, you could refer to when NZTA is
ready to implement, or similar.
For 3.5.1, you may wish to mention that NZTA’s future accreditation of their digital driver licence will
address many of the privacy considerations and requirements noted. Privacy is a substantively
covered by the Digital Identity Services Trust Framework.
OFFICIAL
James Little | Market Development Lead
Digital Identity Services Trust Framework Group
Te Tari Taiwhenua | Department of Internal A airs
s 9(2)(a)
From: Sarah Godwin <[email address]>
Sent: Thursday, 22 May 2025 4:44 pm
To: Monica Rogers <[email address]>; Rachel Townrow <[email address]>; James Little
<[email address]>; [email address]; [email address];
3
[email address]; [email address]; [email address];
[email address]; [email address]; [email address];
[email address]; [email address]; [email address];
[email address]; [email address]; Hayden Glass <[email address]>;
[email address]; Dora Livas (Dora) <[email address]>; [email address];
[email address]; [email address]; [email address]; [email address];
[email address]; [email address]; [email address];
[email address]; [email address]
Cc: Katrina Quickenden <[email address]>; Phoebe Moir <[email address]>; Declan
Lynch <[email address]>
Subject: In confidence - Departmental consultation - Regulatory Systems (Transport) Amendment Bill and draft
Cabinet paper.
Kia ora koutou,
The Ministry of Transport seeks agency feedback on the draft Regulatory Systems (Transport)
Amendment Bill (the Bill) and draft Cabinet paper.
Minister Meager intends to lodge on Thursday 5 June, for consideration at CBC Committee on 9 June.
Ministerial consultation is being progressed simultaneously, to meet this lodgement date.
We would appreciate your feedback by 5pm Thursday 29 May.
ACT 1982
If you have any substantive feedback, we would appreciate this as early as possible.
The Ministry of Transport will continue to work with Parliamentary Council O ice,
agencies, and crown entities on the draft Bill during the consultation period.
The Draft Departmental Disclosure Statement is attached for your information.
Cabinet has agreed to progress the following proposals in the Bill
In March 2025 Cabinet agreed to progress the following policy proposals through the Bill:
enable digital driver licences as a convenient alternative to physical documents and promote
a modern and e icient transport system,
enable electronic issuing of regulatory notices and fees to streamline services that will deliver
significant customer benefits,
INFORMATION
remove unnecessary display requirements to update outdated processes that will reduce
administrative costs,
RELEASED UNDER THE
re-focus our public transport principles to reduce cost and complexity for public transport
decision-makers,
amend errors in the Civil Aviation Act 2023 to empower airports to set charges and cost-
recover fees, in line with the original intent of the legislation.
a number of technical fixes across land transport, maritime and aviation legislation that the
Ministry of Transport developed under the previous Government, and
OFFICIAL
decisions already made by Cabinet to both enable councils to set parking fees below
maximum cap (CAB-24-MIN-0220) and enable adjustments to the Clean Vehicle Standard to
save motoring costs for New Zealanders (CAB-24-MIN-0248).
The Bill gives e ect to the proposals listed above, to maintain and improve the e ectiveness and
e iciency, modernise, and reduce the chance of regulatory failure of the transport regulatory system.
This Cabinet paper seeks approval for the Bill to be introduced, subject to final approval from the
Business Committee. Cross-party support from the Business Committee will be required to progress
the Bill. If any proposals prove contentious, the Minister intends to split these into separate bills.
4
Time-critical Aviation and Clean Vehicle Standard Amendments drive timelines of the Bill
s 9(2)(f)(iv)
Aviation
Amendments to the Civil Aviation Act 2023 are required to correct an error that will exclude
Auckland Airport and Wellington Airport from the ability to set charges under the Act for
aerodrome activities.s 9(2)(g)(i)
Clean vehicle standard
It is necessary to enact the Clean Vehicle Standard amendments this year as Cabinet agreed
to allow the transfer of CO2 emission credits between the new and used-import vehicle
sectors with a 2026 start date for transfers. Currently transfers between the two sectors are
prohibited.
This decision was announced following Cabinet’s decisions on 1 July 2024 and the vehicle
industry is expecting to be able to transfer CO2 emission credits between the two sectors.
s 9(2)(f)(iv)
ACT 1982
Implementation of digital modernisation proposals
While this Bill will progress the necessary legislative changes to enable digital drivers’ licences,
notices, fees and display requirements, implementation for these proposals will take time. The
Minister of Transport will return to Cabinet later this year with more detail on service design and
delivery options, timeframes, and associated costs.
INFORMATION
I appreciate I may have got some contacts wrong - please pass on to the appropriate person in your
RELEASED UNDER THE
agency to respond.
Happy to answer any questions,
Thank you
Sarah Godwin (she/her)
OFFICIAL
Kaitohutohu Matua I Senior Policy Advisor – Regulatory Reform
Te Manatū Waka Ministry of Transport
M:s 9(2)(a)
E: [email address] | transport.govt.nz
5
Document 16
Neha Pawar
From:
JENKISON, Sarah <[email address]>
Sent:
Thursday, 29 May 2025 4:59 pm
To:
Sarah Godwin
Cc:
WHITE, John
Subject:
RE: [EXTERNAL] In confidence - Departmental consultation - Regulatory Systems
(Transport) Amendment Bill and draft Cabinet paper.
Follow Up Flag:
Follow up
Flag Status:
Completed
Kia ora Sarah,
Thank you for giving us the opportunity to provide feedback on the Regulatory Systems (Transport) Amendment Bill
and dra Cabinet paper.
Police do not have any feedback on the Bill or Cabinet paper itself. I believe we previously provided feedback on the
digital modernisation proposals when they were first proposed. We are likely to provide feedback on the
implementation of these proposals as more details come to light. If MOT can please continue to keep us informed of
the progress of these proposals, that would be much appreciated.
ACT 1982
Please do not hesitate to contact me if you have any queries or require any further information.
Ngā mihi,
Sarah
Sarah Jenkison
Policy Advisor
Policy Group
Police National Headquarters
E [email address]
INFORMATION
RELEASED UNDER THE
Duplication of email dated 22 May 2025 from Sarah G
OFFICIAL

Document 17
Neha Pawar
From:
Cori Yap <[email address]>
Sent:
Thursday, 29 May 2025 5:00 pm
To:
Sarah Godwin
Cc:
Phoebe Moir; Declan Lynch; Steve Penman; Amy Moorhead; Darren Baars; Vanessa
Bates
Subject:
RE: In confidence - Departmental consultation - Regulatory Systems (Transport)
Amendment Bill and draft Cabinet paper
Attachments:
NZTA comments for MOT - Regulatory Systems (Transport) Amendment Bill 2025
Approval for Introduction - Cabinet Paper .docx
Categories:
ongoing work
Kia ora Sarah
Thank you for the opportunity to provide comments on the Draft Cabinet Paper for the Regulatory Systems
(Transport) Amendment (RSTA) Bill. Please see attached NZTA’s feedback embedded in the document via
tracked changes.
NZTA feedback on the current draft:
ACT 1982
s 9(2)(g)(i)
The remaining comments in document are largely focused on clarifying language (ie ensuring digital
driver licences are additional not replacements to physical copies) and ensuring overall consistency
across the paper.
Please do not hesitate to reach out if you have any questions about the feedback.
Ngā mihi,
Cori
Cori Alejandrino-Yap
Principal Advisor
INFORMATION
Infrastructure and Stewardship Policy
p
s 9(2)(a)
RELEASED UNDER THE
E [email address] / w nzta.govt.nz
NZ Transport Agency Waka Kotahi
44 Bowen St, Pipitea/Wellington 6011
Private Bag 6995, Wellington 6141, New Zealand
Connect with us on social media
OFFICIAL
From: Sarah Godwin <[email address]>
Sent: Tuesday, 27 May 2025 9:19 am
To: Steve Penman <[email address]>; Eden Christie <[email address]>; Anna Cleary
<[email address]>; Caitlin Sinclair <[email address]>; Xavier Watts
<[email address]>; Jeremy Smith <[email address]>; Grace Bennett
1

<[email address]>; Martien Duis <[email address]>; Andrew Thompson
<[email address]>; Cori Yap <[email address]>
Cc: Phoebe Moir <[email address]>; Declan Lynch <[email address]>
Subject: RE: In confidence - Departmental consultation - Regulatory Systems (Transport) Amendment Bill and draft
Cabinet paper
Some people who received this message don't often get email from [email address]. Learn why this is important
My apologies – This appendix table wasn’t attached to the Cabinet paper that was sent to you. Please
find attached FYI.
Sarah Godwin (she/her)
Kaitohutohu Matua I Senior Policy Advisor – Regulatory Reform
Te Manatū Waka Ministry of Transport
M: s 9(2)(a)
E: [email address] | transport.govt.nz
ACT 1982
From: Sarah Godwin
Sent: Thursday, May 22, 2025 5:30 PM
To: Steve Penman <[email address]>; Eden Christie <[email address]>; Anna Cleary
<[email address]>; Caitlin Sinclair <[email address]>; Xavier Watts
<[email address]>; Jeremy Smith <[email address]>; Grace Bennett
<[email address]>; Martien Duis <[email address]>; Andrew Thompson
<[email address]>
Cc: Katrina Quickenden <[email address]>; Phoebe Moir <[email address]>; Declan
Lynch <[email address]>
Subject: In confidence - Departmental consultation - Regulatory Systems (Transport) Amendment Bill and draft
Cabinet paper
Kia ora NZTA colleagues
INFORMATION
Please note this is shared in confidence and is subject to legal privilege.
RELEASED UNDER THE
The Ministry of Transport seeks feedback from NZTA on the draft Regulatory Systems (Transport)
Amendment Bill (the Bill) and draft Cabinet paper.
The relevant provisions in the Bill have been shared with you. We would appreciate your feedback
by 5pm Thursday 29 May.
OFFICIAL
Minister Meager intends to lodge on Thursday 5 June, for consideration at CBC Committee on 9 June.
Ministerial consultation is being progressed simultaneously, to meet this lodgement date.
If you have any substantive feedback, we would appreciate this as early as possible.
The Ministry of Transport will continue to work with Parliamentary Council O ice,
agencies, and crown entities on the draft Bill during the consultation period.
The Draft Departmental Disclosure Statement is attached for your information.
2

This Cabinet paper seeks approval for the Bill to be introduced, subject to final approval from the
Business Committee. Cross-party support from the Business Committee will be required to progress
the Bill. If any proposals prove contentious, the Minister intends to split these into separate bills.
s 9(2)(f)(iv)
Implementation of digital modernisation proposals
While this Bill will progress the necessary legislative changes to enable digital drivers’ licences,
notices, fees and display requirements, implementation for these proposals will take time. The
Minister of Transport will return to Cabinet later this year with more detail on service design and
delivery options, timeframes, and associated costs.
Thank you,
Sarah Godwin (she/her)
ACT 1982
Kaitohutohu Matua I Senior Policy Advisor – Regulatory Reform
Te Manatū Waka Ministry of Transport
M: s 9(2)(a)
E: [email address] | transport.govt.nz
MINISTRY OF TRANSPORT
Wellington (Head Office) | Ground Floor, 3 Queens Wharf | PO Box 3175 | Wellington 6011 | NEW ZEALAND | Tel:
+64 4 439 9000 |
INFORMATION
Auckland | NZ Government Auckland Policy Office |Level 7, 167B Victoria Street West | PO Box 106238 | Auckland
RELEASED UNDER THE
City | Auckland 1143 | NEW ZEALAND | Tel: +64 4 439 9000 |
Disclaimer: This email is only intended to be read by the named recipient. It may contain information which is
confidential, proprietary or the subject of legal privilege. If you are not the intended recipient you must delete this
email and may not use any information contained in it. Legal privilege is not waived because you have read this email.
Please consider the environment before printing this email.
OFFICIAL
This message, together with any attachments, may contain information that is classified and/or
subject to legal privilege. Any classification markings must be adhered to. If you are not the intended
recipient, you must not peruse, disclose, disseminate, copy or use the message in any way. If you
have received this message in error, please notify us immediately by return email and then destroy
the original message. This communication may be accessed or retained by NZ Transport Agency
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3
Attachment
I N C O N F I D E N C E
In Confidence
Office of the Minister of Transport
Cabinet Legislation Committee
Regulatory Systems (Transport) Amendment Bil 2025: Approval for
Introduction Proposal
1 This paper seeks approval for the introduction of the Regulatory Systems (Transport)
Amendment Bill 2025 (the Bill), subject to agreement of the Business Committee.
ACT 1982
Policy
2 This omnibus Bill contains amendments to land transport, maritime and aviation
legislation and aims to:
2.1
maintain and improve the effectiveness and efficiency of the transport
regulatory system;
2.2
modernise the transport regulatory system; and
2.3
reduce the chance of regulatory failure.
3 The Bill will achieve these objectives by:
3.1
addressing transport regulatory duplication, gaps, errors, and inconsistencies
within transport legislation;
3.2
ensuring that regulators have effective tools to keep the transport regulatory
system up to date and relevant, including modernising legislation to enable
INFORMATION
convenient digital service alternatives to physical licences and labels;
3.3
removing unnecessary compliance costs from the transport system.
RELEASED UNDER THE
4 The Bill gives effect to policy proposals agreed to by Cabinet on 31 March 2025 (CAB-
25-MIN-0086 refers) to amend legislation to:
Commented [EC1]: If NZTA implements the Austroads'
digital driver licence solution, physical driver licence
4.1
enable digital driver licencses as a convenient alternative toin addition to
cards wil continue to be issued to customers and it's
physical documents and to promote a modern and efficient transport system,
likely most customers wil need to use the physical card
during the identity proofing process for a DDL. Although
the intention is that customers wil be able to use their
4.2
enable electronic issuing of regulatory notices and fees to streamline services
DDL for the same purposes as the physical card, the
to deliver system efficiencies and customer benefits,
DDL wil be complimentary to the physical card (ie not
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issued as a stand alone document)
4.3
enable digital alternatives to existing remove unnecessarypaper-based display
Out of Scope
requirements (such as Warrant of Fitness and Certificate of Fitness), where
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link to page 30
I N C O N F I D E N C E
digital alternatives are available, to update outdated processes and reduce
administrative costs,
Out of Scope
4.4
re-focus public transport principles to reduce costs and complexity for public
transport decision-makers, and
4.5
address minor drafting errors in the Civil Aviation Act (CAA) 2023 to
empower airports to set charges and cost-recover fees, and correct
inconsistencies in the Transport Accident Investigation Commission Act
(TAICA) 1990 in line with the original intent of the legislation.
5 The Bill also gives effect to:
5.1
policy proposals agreed to by Cabinet in June 2024 to enable councils to set
parking fees below a maximum cap (CAB-24-MIN-0220 refers);
5.2
policy proposals agreed to by Cabinet in July 2024 to change the Clean
Vehicle Standard to enable greater flexibility and reduce compliance costs
(CAB-24-MIN-0248 refers); and
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5.3
technical amendments to legislation that were developed by the Ministry of
Transport under the previous Government (CAB-22-MIN-0177 refers) and
endorsed by Cabinet on 31 March 2025.
Commented [OK4]: Suggest including a CAB Minute
here if you have one
6 Amendments to transport legislation in the Bill span across land, maritime and aviation.
A summary of the full list of policy proposals included in the Bill is attached in Annex 1.
7 Most of the matters included in the Bill are unlikely to be contentious and there will be
adequate opportunity for the public to engage during the select committee process.
Some proposals in the Bill could be considered contentious
8 The proposal to
remove three public transport principles from Part 5, Section 115 of
the Land Transport Management Act (LTMA) 2003, may be considered contentious
1.
Removing these principles does not prohibit participants in the sector from continuing to
pursue these outcomes and attributes of public transport. The Government Policy
Statement on Land Transport 2024, procurement guidance and letters of expectation, will
INFORMATION
continue to play an important role in supporting the sector to deliver efficient and
effective public transport services.
RELEASED UNDER THE
9 The proposals to enable
digitiseal alternatives for licences and labels to enable broader
Commented [VB5]: Suggested wording change as this
policy change may be considered contentious due to potential privacy concerns, given
should refer to 'enabling' digital licences and labels
these proposals would enable a new way to hold and use personal information. Further
1 This proposal would remove the following three principles:
(1)(a) – well-used public transport services reduce the environmental and health impacts of land transport,
including by reducing reliance on single-occupant vehicles and using zero-emission technology;
(1)(b) – public transport services support a mode shift from private motor vehicle use and equitable access to
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places, facilities, services, and social and economic opportunities if they are co-ordinated, integrated, reliable,
frequent, accessible, affordable, and safe; and
(1)(c) – fair and equitable employment or engagement of people in the public transport workforce should ensure
that there is a sufficiently robust labour market to sustain and expand public transport services.
2
I N C O N F I D E N C E
I N C O N F I D E N C E
due diligence and privacy analysis will be carried out prior to implementation, and
privacy and security will be considered as part of service design and delivery options.
10 Some of the proposed
adjustments to the Clean Vehicle Standard (the Standard) may
be considered contentious given last year’s easing of CO2 targets, and that consultation
undertaken during the review of the Standard was targeted.
11 The select committee process will provide the opportunity to hear from anyone that may
be affected by these proposals.
12 The Bill is not a type of omnibus Bbill that may be introduced under Standing Order 266
or 267(1)(a) or (b). Consequently, the Business Committee must agree to the Bbill’s
introduction as an omnibus Bbill under Standing Order 267(1)(c). If the Business
Committee identified any proposals that it does not agree with, I will remove them to
s 9(2)(f)(iv)
.
I seek Cabinet’s confirmation to additional maritime and Clean Vehicle Standard decisions
13 On 31 March 2025, Cabinet granted me authorisation to make additional policy decisions
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that are consistent with the overall policy intent, subject to Cabinet’s confirmation (CAB-
25-MIN-0086 refers). I have made the following decisions based on this authorisation and
seek confirmation from Cabinet to:
13.1
[subject to your approval in cover brief] remove the proposal to ‘
revise and
reorganise Part 3 of the Maritime Transport Act (MTA) 1994 to align it with
requirements set under the Maritime Labour Convention (MLC) 2006’.
Further analysis is required by the Ministry of Transport and Maritime New
Zealand to address potential unintended consequences of this proposal on the
rights and obligations of masters on ships. The Bill will continue to progress
other proposals to align our domestic legislation with the MLC.
13.2 revoke redundant Infringement Fees for Offences Regulations made under
section 699A of the Local Government Act 1974. Four Regional and District
Councils (Wellington, Canterbury, Marlborough and Taranaki) have updated
their navigation bylaws since their corresponding Regulations were made. The
previous navigation bylaws, to which each of the Infringement Fees for
Offences Regulations relate, are therefore no longer in force and the
INFORMATION
Regulations are redundant.
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13.3 progress amendments to Maritime (Offences) Regulations 1998 and the
Maritime Protection (Offences) Regulations 1998, following amendments to
the MTA in the Bill. Further policy analysis is required for the necessary
changes to be made to these regulations, which my officials will advise me on.
13.4 CO2 emission credit transfers between the new and used-import sectors, under
the Clean Vehicle Standard, occur with an “exchange rate” of two for one (i.e.
a credit earned on a new vehicle would be worth twice as much as one earned
on a used-import).
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Impact analysis
14 Regulatory Impact Statements (RIS) were previously provided to Cabinet on the
following proposals in the Bill:
Commented [KH6]: Wasn't electronic service also
considered?
14.1 state Highway closure powers and Transport Service Licence enforcement
powers,
14.2 the proposal to provide the rail regulator, the New Zealand Transport Agency
with reactive investigatory powers,
Out of Scope
14.3 improvements to the powers of the Director of Land Transport to respond to
emergency and time-critical events,
14.4 the maritime proposals to modernise the penalties for the safety offences in the
Maritime Transport Act 1994, and
14.5 changes to the Clean Vehicle Standard.
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15 All RISs completed to date have received a meets or partially meets assessment by an
independent quality assurance panel.
16 Annex 1 provides a list of the policy proposals which have been exempted from RIS
requirements on the grounds that proposals have no or only minor impacts on businesses,
individuals, and non-for-profit entities, or only minor economic, social or environmental
impacts, or could be suitable to be included in a Statutes Amendment Bill (as provided for
in Standing Orders).
A post-implementation review is required for the proposal to re-focus public transport
principles
17 No RIS was provided for the proposal to remove three public transport principles from
Part 5, Section 115 of the LTMA. This proposal is not exempt from RIS requirements and
consistent with Cabinet’s impact analysis requirements, a post-implementation review
will be undertaken and provided to Cabinet in due course. The Ministry for Regulation
and the Ministry for Transport will discuss and agree on the appropriate scope and timing
of this assessment.
INFORMATION
Consultation
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18 The following agencies were consulted on the contents of this paper:
[TBC] Civil
Aviation Authority, Department of Internal Affairs, Department of the Prime Minister
and Cabinet, Maritime New Zealand, Ministry of Justice, Ministry of Primary Industries,
Ministry for Regulation, New Zealand Police, NZTA, Office of the Privacy
Commissioner, Parliamentary Counsel Office and Treasury.
19 Public consultation took place between 1 June and 8 July 2022 on a package of 33
proposals to amend legislation across land and maritime modes (CAB-22-MIN-0177 and
DEV-22-MIN-0110 refers). Feedback was received from 23 submitters comprising
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industry and sector representative groups, territorial authorities (district and regional
councils), and sector participants. There was generally a high level of support from the
transport sector and local government for the proposals.
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I N C O N F I D E N C E
20 Proposals including introducing a digital driver licence, altering the Clean Vehicle
Out of Scope
Standard, facilitating the NZTA to email regulatory notices and fees, and revising the
public transport operating principles have not been consulted on publicly.
21 I do not propose to take further targeted or public consultation on the proposals in the
Bill. I believe there will be adequate opportunity for the public to engage during the select
committee process.
22 Annex 1 details the proposals in the Bill that have had public consultation.
Binding on the Crown
23 The Bill amends the Government Roading Powers Act 1989, Land Transport Act 1998,
LTMA, MTA, Railways Act 2005, CAA and TAICA which bind the Crown. An
exception to this is provided in section 4 of the MTA, which specifies how the MTA
applies to ships and aircrafts used for defence and governmental purposes.
24 The Bill will be binding on the Crown, noting the exceptions provided in section 4 of the
MTA, is consistent with the approach of the legislation that the Bill amends.
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Creating new agencies or amending law relating to existing agencies
25 The Bill will not create any new agencies and will not amend the existing coverage of the
Ombudsman Act 1975, the Official Information Act 1982, or the Local Government
Official Information and Meetings Act 1987.
Associated regulations
Out of Scope
26 No regulations are needed to bring the Bill into operation.
27 It is possible that regulations will be needed at a later date to implement proposals related
to the Bill. For example, regulations may be needed to set higher levels of fees, as
enabled by the Bill, or to update offences and penalties related to the digitisation
proposals. If there is a need for future regulations, I intend to return to Cabinet to seek
further policy decisions.
Other instruments
INFORMATION
28 The digital modernisation proposals enabled through the Bill will require subsequent rule
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changes to implement.
Commented [KH11]: As will the digital driver licence
proposals.
Definition of Minister/department
29 The Bill does not contain or change a definition of Minister, department (or equivalent
government agency), or chief executive of a department (or equivalent position).
Commencement of legislation
30 The Bill is drafted to commence on 1 January 2026.
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Parliamentary stages
31 I propose that the Bill be introduced in June 2025 s 9(2)(f)(iv)
.
32 There are two time-critical proposals driving the timeframes of the Bill:
32.1 the Clean Vehicle Standard needs be in force by the end of the year to deliver
as we have committed.
32.2 amendments to numbering errors in the Civil Aviation Act 2023 need to be
made as soon as possible to ensure airport operators can carry out important
operational functions such as cost recovery of fees.
33 I propose that the Bill goes through a four month Select Committee process and be
referred to the Transport and Infrastructure Select Committee.
34 The proposed timeline for the Bill is as follows:
Milestone
Timeframe
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Business Committee
Post cabinet consideration on 16 June
2025
Introduction of Bill
Late June 2025
Select Committee
Late June – Late October 2025
s 9(2)(f)(iv)
Proactive Release
35 This Cabinet paper and its corresponding minute will be proactively released within 30
business days of final policy decisions being taken by Cabinet.
INFORMATION
Recommendations RELEASED UNDER THE
I recommend that the Cabinet Legislation Committee:
1
note that the Regulatory Systems (Transport) Amendment Bill (the Bill)s 9(2)(f)(iv)
2
note that the Bill will make amendments across transport legislation to support
effective regulatory stewardship and an efficient transport system;
3
confirm the delegated policy decisions I h
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previously received from Cabinet (CAB-25-MIN-0086 refers).
6
I N C O N F I D E N C E
I N C O N F I D E N C E
4
approve the Bill for introduction, subject to the final approval from the Business
Committee;
5
note that if any proposals in the Bill need to be removed in order for it to receive the
Business Committee’s agreement to its introduction, the Bill may be amended prior to
introduction to remove these proposals;
6
note that if any proposals are removed from the Bill under recommendation 5, the
relevant Minister will return to the Cabinet Legislation Committee to seek decisions
on alternative legislative vehicles for these proposals;
7
agree, subject to final approval from the Business Committee, that the Bill:
7.1
is referred to the Transport and Infrastructure Select Committee for
consideration; and
7.2 s 9(2)(f)(iv)
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Authorised for lodgement
Hon James Meager
Associate Minister of Transport
INFORMATION
RELEASED UNDER THE
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Summary table of proposals of Regulatory Standards
(Transport) Amendment Bil 2025
Proposal
Description
Legislation to be
Relevant RIS
Public
amended
clause in requirements
consultation
RSTA Bil
Y/N
Land transport proposals
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Highway and
Provide the NZ Transport Agency (NZTA) with broader powers Government
TBC
RIS included for Y
Motorway
to close parts of the State Highway network to address safety
Roading Powers Act
boarder power
Amendments
concerns.
1989; Land
proposal.
Amend a mistake which prevents NZTA from declaring newly
Transport
Exempt for
built roads into a state highway.
Management Act
other
2003
Clarify that pedestrians may use approved areas
proposals.
and infrastructure within motorway corridors. E.g. bus stops.
Modernising the
Create a new offence and an associated fine for transferring,
Land Transport Act TBC
RIS included
Y
enforcement
assigning or leasing a TSL.
1998; Land
regime for
Transport
Transport Service
Create a new power to enable NZTA to audit someone
(Regulatory Fees)
Licences (TSL)
purporting to operate a transport service without a licence.
Regulations 2023,
Enable the immediate suspension of a TSL for health and
the Land Transport
safety concerns, when significant concerns are recognised or
(Offences and
reported.
Penalties)
INFORMATION
Require a fit and proper person check for any new person in
Regulations 1999
control of a transport service, which is required to be
and Land Transport
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documented for a TSL.
Rule: Operator
Licensing 2017.
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Simplifying the
Clarify the consultation and notification requirements in rule-
Land Transport Act TBC
Exempt
Y
rule consultation
making powers in the Land Transport Act 1998
1998
process to increase
consistency
Increasing
Increase the maximum level of fines and infringement fees
Land Transport Act TBC
Exempt
Y
maximum fines
that can be set through regulations. The Ministry of Transport 1998
and infringement
developed the Effective Financial Penalties Framework and
fees
Financial Penalties Categorisation Tool. The Bill will increase
the maximum level of fines and infringement fees to align with
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this framework and tool.
Declaration of
Strengthen the process through which NZTA can declare
Land Transport Act TBC
Exempt
N
Motor Vehicles
vehicles to not be a ‘motor vehicle’ under the Land Transport
1998
Act 1998. This change will improve the workability and
transparency of the declaration process which has previously
come under scrutiny regarding the E-Scooters (Declaration Not
to be Motor Vehicles) Notice 2018.
Enabling parking
Enable local authorities to set infringement fees
Land Transport Act TBC
RIS Included
N
fines below a
for overstaying in a carpark below a maximum cap. This
1998; Land
maximum cap
proposal fixes a technical issue with the Land Transport Act
Transport (Offences
1998 to give local authorities the necessary powers to set
and Penalties)
these lower fees, as it was original y intended.
Regulations 1999
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Director
Create new powers for the Director of Land Transport to
Land Transport Act TBC
RIS Included
N
emergency powers respond to emergency and time critical events. The Director's
1998; Land
ability to waive regulatory requirements for time-
Transport Rule:
critical emergency situations is currently restricted. The Bill will Vehicle Standards
expand these. e.g., extend the term of land transport
Compliance 2002
documents (such as drivers licenses), or require vehicles to
presented for inspection (e.g. for a Warrant of Fitness) if a
safety issue has been identified.
Reactive
Introduce new reactive investigation powers for NZTA to
Railways Act 2025
TBC
RIS Included
Y
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investigation
investigate more effectively and efficiently, following rail
powers under the accidents and incidents. For example:
Out of Scope
Railways Act 2005
• freeze a scene to preserve and col ect evidence;
• access sites to investigate or carry out
verification inspections;
• request materials to be supplied for examination;
• interview personnel involved in a safety occurrence
and;
• require identified failings to be remediated by the rail
participant.
Remove time
Pause the statutory timeframes when further information is
Railways Act 2025
TBC
Exempt
Y
constraints for rail required from an applicant in relation to a Rail Safety Case,
safety case
either for a new application or a variation to an existing safety
INFORMATION
application process case. This ‘stop-the-clock’ provision al ows enough time for
information to be gathered. Reducing prescriptive timeframes
RELEASED UNDER THE
for information will make this process more efficient.
Digital modernisation proposals
10
I N C O N F I D E N C E
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I N C O N F I D E N C E
Enabling Digital
Enable the future implementation of digital driver licences.
Land Transport Act TBC
Exempt
N
Driver Licences
This includes amending sections that require a physical licence. 1998
(DDL)
This change supports the Digitising Government approach that
aims to promote a modern and efficient public service.
Out of Scope
Better enabling
Better enable the electronic issuing of infringements and other Land Transport Act TBC
Exempt
N
NZTA to email
regulatory notices. This would include requiring the provision
1998
regulatory notices of email addresses, mobile phone numbers, and the current
and fees
requirements for postal addresses.
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Enabling digital in- Enable electronic alternatives to requirements to carry and
Land Transport Act TBC
Exempt
N
vehicle labels
display physical licences and labels, including Warrants of
1998; Land
Fitness (WOFs), Certificates of Fitness (COFs) and alternative
Transport (Motor
fuel inspection certificates.
Vehicle Registration
and Licensing)
Regulations 2011,
Land Transport
(Offences and
Penalties)
Regulations 1999
Public transport principles proposal
Remove public
Remove three public transport principles from the
Land Transport
TBC
Post
N
transport
Land Transport Management Act 2003 to reduce compliance
Management Act
implementation
principles
costs and improve regulatory certainty for public transport
2003
review required
decision makers.
INFORMATION
Clean Vehicle Standard proposals
RELEASED UNDER THE
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I N C O N F I D E N C E
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I N C O N F I D E N C E
Extending the
Extend the lifespan of CO2 emission credits that are earned on Land Transport Act TBC
RIS Included
N –
lifespan of
low emission vehicles from three years to four years. This will
1998; Land
Targeted
emission credits
encourage importers to overachieve targets, when possible, to Transport (Clean
engagement
increase credit buffers against future target
Vehicle Standard)
with
underachievement.
Regulations 2022
industry
Remove restriction Remove the legislative restriction on credit transfers between Land Transport Act TBC
RIS Included
N –
on credit transfers the new and used import sectors, with a 2026 start date for
1998
Targeted
between new and transfers. This recognises that new low emission vehicles will
engagement
used importers
be in use for on average, twice the period of time of an
with
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average used-import low emission vehicle. A credit earned on
industry
a new vehicle is to be worth twice as much as one earned on a
used vehicle.
Remove restriction Enable future targets to be set that are ‘uniform’ and not
Land Transport Act TBC
RIS Included
N –
on weight-
adjusted for vehicle weight. As the number of zero and low
1998
Targeted
adjusted targets
emission vehicles increases, the linear relationship between
engagement
vehicle weight and a vehicle’s CO2 emissions will become
with
weaker. It is important to stop weight-adjusting targets when
industry
there is no material linear relationship, to prevent distortion of
the vehicle market. This proposal enables both uniform and
weight-adjusted targets to be set with the expectation that
weight-adjusted targets will eventual y be replaced with
uniform targets.
INFORMATION
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I N C O N F I D E N C E
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I N C O N F I D E N C E
Extending
Extend the use of borrowing future target overachievement
Land Transport Act TBC
RIS Included
N –
payment
(payment obligation deferral) beyond 2025 (currently this
1998
Targeted
obligation deferral provision is only available until 2025).
With borrowing,
engagement
beyond 2025
importers who do not achieve their annual target can make up
with
the underachievement the fol owing year by overachieving the
industry
subsequent year’s target by an equal amount. This flexibility
only applies to importers that comply on an annual basis
(category 1 light vehicle importers).
Aviation proposals
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Correct numbering Correct a numbering error which unintentionally disapplied
Civil Aviation Act
TBC
Exempt
N
errors in the Civil
sections preventing airports to set charges. This proposal
2023
Aviation Act 2023
clarifies that costs can not be recovered via levies where those
same costs are otherwise collected and makes a minor
editorial change to cross-references.
Correct errors in
Correct an error where “accident” and “accident and incident” Civil Aviation Act
TBC
Exempt
N
the Transport
are referred to inconsistently in the TAIC.
2023
Accident
Investigation
Transport Accident
Commission Act
Investigation
(TAIC) 1990
Commission Act
(TAIC) 1990
Maritime proposals
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I N C O N F I D E N C E
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I N C O N F I D E N C E
Amend and
Amend the threshold for initiating an investigation from
Maritime Transport TBC
Exempt
Y
expand
‘reasonable grounds to believe’ to ‘reasonable grounds to
Act 1994
investigation
suspect.’ This will allow Maritime NZ to conduct an
powers
investigation when it has reasonable cause to do so, but
without requiring near certainty as under the current standard
of ‘belief’.
Allow investigations under section 54A of the Act for non-
compliance with the general duties for participants in the
maritime system under section 17. This will support the
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existing power under section 43 to suspend a maritime
document on the grounds of non-compliance with the
requirements of section 17. This proposal will also provide
clarity and certainty to Maritime NZ in carrying out its
regulatory oversight of maritime document holders.
Update and amend Align maritime penalties with the effective transport-related
Maritime Transport TBC
RIS included
Y
maritime fines,
financial penalties policy framework to ensure penalties are
Act 1994
infringement fees
consistent with international standards and are fair and
and offences
effective. This includes:
• Increasing maximum level of fines and infringement
fees.
• Updating the maximum financial penalties available
for safety offences.
• Revoking bylaw infringement offence regulations
that relate to revoked or replaced bylaws.
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I N C O N F I D E N C E
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I N C O N F I D E N C E
Technical maritime Amend a technical problem with the definition of ‘unit of
Maritime Transport TBC
Exempt
Y
fixes
account’ in section 2 of the MTA, to remedy a lack of clarity.
Act 1994
Clarify the requirement for operators of a floating production
storage and offloading unit (FPSO) to be required to pay
the maritime levy. When a FPSO does enter our waters, they
will contribute to our maritime regulatory system to ensure
safety and environmental protection through the levy
payment.
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Aligning Maritime Fix inconsistencies between the MTA and MLC relating to:
Maritime Transport TBC
Exempt
Y
Transport Act 1994
Act 1994
with the Maritime
• Records of Employment that do not reference quality
Labour Convention
of work.
(MLC)
• Prohibiting people younger than 16 years old from
working on a ship and people under 18 from
undertaking hazardous work.
• The definition of employment agreements.
• Clarify that seafarer recruitment can take place and to
ensure that ship owners, not seafarers, are charged for
this service.
• Clarify the scope of rule-making powers to align with
relevant aspects of the MLC.
Updating service
Enable documents and notices required to be served on any
Maritime Transport TBC
Exempt
Y
requirement for
person under the MTA. This includes infringement notices to
Act 1994;
electronic service
be served through traditional paper-based means or through
Marine Protection
INFORMATION
of documents
electronic service. This future-proofs the regulatory framework (Offences)
and enables cost savings for the regulators.
Regulations
1998; Maritime
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(Offences)
Regulations 1998
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Simplifying the
Clarify the consultation and notification requirements in rule-
Maritime Transport TBC
Exempt
Y
rule consultation
making powers in the MTA.
Act 1994
process to increase
consistency
Minister of
Enable the Minister of Conservation to exercise functions,
Maritime Transport TBC
Exempt
Y
Conservation
duties, and powers under Part 3A of the MTA in
Act 1994
powers in
the Subantarctic and Kermadec Islands as if they were a
Subantarctic
regional council or unitary authority. This will allow the
and Kermadec
Minister of Conservation to manage maritime safety at the
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Islands
Islands
e.g.
the appointment of a Harbour Master and
navigation bylaws. This will provide greater safety and
assurance for masters, crew and passengers of ships operating
the waters surrounding the Islands.
Update definition
Update the definitions of ‘convention’ and ‘marine protection
Maritime Transport TBC
Exempt
Y
of “convention”
convention’ in the MTA to ensure that when a convention that Act 1994
has previously been declared as a convention under the Act,
no further declaration through an Order in Council is required.
This will avoid unnecessary administrative procedures when
New Zealand agrees to amendments to Conventions.
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Document 18
Out of Scope
From: Katrina Quickenden <[email address]>
Sent: Thursday, 10 April 2025 4:54 pm
To: Greig Epps <[email address]>; Justin Tighe-Umbers <[email address]>;
[email address]; [email address]; [email address]; [email address]; David Boyce
<[email address]>; Terence J. Collins (AA) <[email address]>; Jonathan Bhana-Thomson
<[email address]>
Cc: Jacob Ennis <[email address]>; Laura Bender <[email address]>; Paul O'Connell
<P.O'[email address]>; Amy Moorhead <[email address]>; Mike Hargreaves
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<[email address]>
Subject: IN CONFIDENCE: Draft transport rules reform work programme
Kia ora koutou
The Minister has approved us sharing the attached draft summary of the rules reform work programme, for
your review and feedback. Please keep this in-confidence, not distributing this beyond your organisation.
We would appreciate feedback by 22 April to feed into advice we're planning to send to the Minister on
finalising the scope of the work.
We do very much appreciate the time you've taken to provide specific proposals for reform. We believe we
have incorporated the bulk of these, so if you feel something important is missing, please do let us know.
INFORMATION
Amy and I are happy to meet with any of you to discuss the work.
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Kind regards,
Katrina
Katrina Quickenden
Manager - Regulatory Reform Team |
OFFICIAL Kaiwhakahaere
Te Manatū Waka Ministry of Transport
M:s 9(2)(a)
E: [email address] | transport.govt.nz
1
IN CONFIDENCE: NOT FOR WIDER CICULATION
April 2025
DRAFT RULES REFORM WORK PROGRAMME
This programme of work has been developed based on the priorities you and other transport sector
stakeholders identified including through a series of meetings and submissions sent to the Ministry
and NZTA in 2024. Thank you for your engagement and input we are pleased to share the resulting
work programme with you for your feedback. Timing is indicative, and may change as the work
progresses.
We have bundled up the issues you and others raised into workstreams. We have found a place for
most of the suggestions we heard. If you do not see something you raised, it may stil be included in
the work. Please let us know if something important is missing and we will point you to where it is
included if it is under a different heading or project, may be able to find a way to add it in, or will
explain why it has not been prioritised at this time.
Some items have been excluded from the immediate work programme because:
• They require substantial analytical work and/or reform of primary legislation and cannot be
completed alongside the substantial/longer-term work already included in the work
programme (e.g. a major overhaul of the Transport Service Licence regime).
• We evaluated them to be a lower priority for the sector, had not previously scoped the work,
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or did not have immediate resource available to progress it. If you feel we have left out
something critical, please let us know.
• The issue did not relate to transport rules, particularly if not a part of the transport portfolio
(e.g. immigration settings and Health and Safety at Work Act 2015 issues).
What follows is a list of rule reform proposals organised under the following focus areas:
• Updating vehicle inspection requirements
• Modernising and digitising transport services and licencing
• Growing road freight productivity
• Overhaul of vehicle system and import requirements and ongoing regulatory stewardship.
INFORMATION
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Updating vehicle inspection requirements
New Zealand’s vehicle inspection system is not as effectively targeted to risk as it could be. We check
some things too often and other high-risk issues insufficiently or not at all. A rebalancing of
inspection frequency with improvements to testing could make the system more fit-for-purpose and
lower some compliance costs. Two projects are proposed:
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Reduce vintage and motorhome inspection frequency
• Consultation: Started in February 2025 and closed 4 April 2025
• Scope
: Review of frequency of inspections for vintage/veteran vehicles and privately owned
heavy motorhomes.
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April 2025
Reviewing Warrant of Fitness requirements for light vehicles and Certificate of Fitness requirements
for light rental vehicles
• Consultation: October/November 2025.
• Scope
: Review of what gets inspected and frequency of inspections for light vehicles and
when WOF v COF applies.
Modernising and digitising transport services and licencing
Our transport regulatory system involves too many paper notices, stickers, and licences. We are
looking to enable digital alternatives to many documents, stickers, licences, etc. We are also wanting
to improve our driver licensing system. Three projects are proposed:
Enable digital documents, e-servicing, and other service improvements
• Consultation: February/March 2026 for the Rules, with enabling primary legislation planned
for 2025.
• Scope:
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o Enabling digital labels for Motor Vehicle Licence, WoF/CoF, Transport Service
Licence, Alternative Fuel Certificate, Certificate of Loading (note RUC label
digitisation is progressing separately as part of the transition to RUC work
programme)
o Improving NZTA customer service by enabling more flexibility in legislation governing
temporary licences, including enabling digital formats and longer validity periods
(e.g. for RUC licences) and online theory tests
o Enabling better e-servicing of transport related notices (e.g. infringements) to be
sent via email or text, or to the NZTA App instead of to physical addresses
o Improving identity requirements for driver licencing services to include new forms of
INFORMATION
identification.
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Enable a digital driver licence
• Consultation: Late 2025 or early 2026
• Scope: Enabling a digital driver licence that can be used as well as or instead of a physical
licence.
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Improve driver licensing
• Consultation: Completed in 2019, may need to be consulted on again in mid 2025.
• Scope:
o Simplifying the progression from Class 2 – 5 licences
o Reviewing the Accelerated Licensing Process
o Reviewing the requirements for special-type vehicle endorsements
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o Standardising speed thresholds for tractors and special-type vehicles
o Simplifying the rules for tractors that can be driven on a Class 1 licence
o Considering automatic renewal of general licences for some endorsement holders.
Note a separate review of the Graduated Driver Licencing System is underway covering a range of
other improvements.
Growing road freight productivity
Freight drives economic productivity in New Zealand. It is subject to many outdated rules and
regulations which often fail to target regulatory effort to risk and have become obstacles to
technology change. Three projects are proposed:
Freight permitting reform
• Consultation: October 2025
• Scope:
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o 50MAX permitting reform including reviewing the requirement for a permit to
operate a 50MAX vehicle up to 50 tonnes
o Reviewing the requirement to display an H plate
o Consider enabling over-dimension vehicles to operate on tol roads and Auckland
Motorways
o Reviewing permitting approach to enable rental stock to be delivered “just in time”
o Reviewing settings for enabling HPMV vehicles to carry over-dimension loads
o Review HPMV proforma permit requirement for vehicle recovery licence holders
o Review of load pilots licences
INFORMATION
o Improve pilot vehicle rooftop signs.
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Licence weight thresholds and immigrant driver settings
• Consultation: February/March 2026
• Scope:
o Review and consider adjusting the weight threshold between Class 1 and Class 2
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licences – to better match licence classes to risk.
o Review the heavy vehicle licencing pathway for immigrants.
Comprehensive review of the Vehicle Dimension and Mass Rule
• Consultation: TBC in 2027. This timeframe is due to the complexity of assessing the road
maintenance issues associated with greater vehicle/axle weights and alternative
configurations. This will have an impact on RUC and driver licensing settings and future NZTA
decision making on roading design.
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April 2025
• Scope:
o Review vehicle weight settings to better enable more productive trucks and low
emission heavy vehicles
o Review maximum vehicle width and height
o Consider enabling 6X2 prime movers to operate at gross mass limits up to 50 tonnes
Overhaul of vehicle system and import requirements
New Zealand aligns most of its vehicle regulation with other jurisdictions since we have limited
influence over the international vehicle market. We could look to reduce complexity through greater
and/or more automatic recognition of standards in these jurisdictions. This could include refocusing
our import requirements on the areas of highest impact. These potential changes could also be a
starting point in overhauling the regulatory framework, consolidating rules and ensuring the system
is agile and well adapted for the future.
Mandating modern vehicle safety features
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• Consultation: June/August 2025
• Scope: This aims to improve the safety and quality of the vehicle fleet over time by
mandating certain features. This may include AEB, LKS, ESC, and AVAS.
Overhaul of import requirements and vehicle regulatory system
• Consultation: May/June 2026 (on high level proposals)
• Scope:
o Type approval and harmonisation with/automatic recognition of international
standards and/or requirements
o Overhaul of vehicle regulatory system with the aim of making our regulatory
INFORMATION
approach more agile and enabling. This may include shifting away from prescriptive
rules and towards more performance-based regulation, removing an
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large numbers of rules, and limiting the focus/scope of the regulatory system.
o This work programme may include multiple smaller changes, including reviewing
lighting requirements, vehicle definitions e.g. trailers.
Minor system improvements
OFFICIAL
We will progress consultation on various minor proposals. For example:
• Allow for integral trailer brake control units on medium trailers
• Remove unintended movement restrictions on mobile cranes
• Add compliance with an approved standard as an alternative method of compliance for
indirect steering systems.
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Document 19
Out of Scope
From: Dom Kalasih <[email address]>
Sent: Wednesday, 23 April 2025 5:01 pm
To: Katrina Quickenden <[email address]>
Subject: FW: IN CONFIDENCE: Draft transport rules reform work programme
Hi Katrina
Thank you for the small extension to provide our feedback after yesterday’s deadline. It was much
appreciated
I have attached Transporting New Zealand’s feedback and if it is of any help, I would welcome further
discussion on it.
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Kind regards
Dom Kalasih
Chief Executive
Ia Ara Aotearoa Transporting New Zealand
INFORMATION
Transporting New Zealand
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Level 3 93 Boulcott St
PO Box 1778
Wellington 6140
P: +64 4 471 8285
M: +64 27 441 4309
E: [email address]
OFFICIAL
W: www.transporting.nz
Duplicate of email dated 10 April 2025 from Katrina Q
23 April 2025
Katrina Quickenden
Manager – Regulatory Reform Team
Ministry of Transport
Sent by email: [email address]
Dear Katrina
Thank you for the opportunity to comment on the draft summary of the rules reform work
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programme and the advice to the Minister finalising the scope of that work.
I appreciate the work done by your team and NZTA over the last 12 to 18 months in this
regard. We agree with the approach of organising the reforms under the four focus areas.
It is also very helpful for us to see an indicative plan of when consultation on the respective
areas is intended.
Our comments on the four areas follow
Out of Scope
INFORMATION
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OFFICIAL
Transporting New Zealand, PO Box 1778, Wellington 6140, Level 3, 93 Boulcott Street, Wellington, 6011.
Telephone: (04) 472 3877, Email
: [email address], Website: www.transporting.nz
1
Out of Scope
2. Modernising and digitising transport services and licencing
a) Enabling digital documents, e-servicing and other service requirements Feb/Mar 2026
b) Enable a digital driver licence Late 2025 /early 2026
We support these proposals in principle. We think it is good to keep up with modern practice
and we are aware a number of other countries are taking this path.
c) Improve driver licensing Mid 2025
We strongly support this proposal.
We recommend that there should be consultation around the middle of 2025 and that at the
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same time the driver licence projects currently listed in in the
Growing road freight
productivity section, namely the review of the Class 1 threshold and the heavy vehicle
licensing pathway for migrants, should be integrated with this work.
Out of Scope
INFORMATION
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OFFICIAL
Transporting New Zealand, PO Box 1778, Wellington 6140, Level 3, 93 Boulcott Street, Wellington, 6011.
Telephone: (04) 472 3877, Email
: [email address], Website: www.transporting.nz
2
Out of Scope
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INFORMATION
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OFFICIAL
We envisage the changes proposed in 2 a) and 2 b) may bring benefits, predominantly to
compliance and enforcement. However, as with the changes above, in our opinion this
change wil make negligible difference to productivity.
Transporting New Zealand, PO Box 1778, Wellington 6140, Level 3, 93 Boulcott Street, Wellington, 6011.
Telephone: (04) 472 3877, Email
: [email address], Website: www.transporting.nz
3
We support the proposed change in 2 c) because we envisage these changes wil reduce
the barriers, particularly the cost and time, for drivers to obtain a heavy vehicle combination
licence. As the economy recovers and more work, such as road construction, gets underway
we anticipate our industry wil experience a driver shortage therefore this change will make a
meaningful dif erence.
Out of Scope
We are also concerned that with an election expected in late 2026, that traditionally tends to
adversely impact the progress of legislative change, which could further delay any
meaningful progress on the VDAM Rule as currently scheduled.
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In summary, while we agree that all the proposals are beneficial, our concern is that the
current order and prioritisation of the work programme does not reconcile with maximising
the benefits to the nation. Despite considerable advancements in both heavy vehicle
technology and trailer engineering it is about a decade since there was any significant
change to the VDAM and our fear is that the opportunity cost of further delays to enabling or
industry and nation to realise these benefits is not being fully appreciated by officials.
Transporting New Zealand would welcome further constructive collaboration with the
Ministry of Transport on the implementation plan to ensure these rule changes, in particular
that on VDAM reform, can progress as quickly as possible.
Please don’t hesitate to contact me if we can be of any help in this regard.
INFORMATION
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Yours sincerely
Dom Kalasih
OFFICIAL
Chief Executive
Ia Ara Aotearoa Transporting New Zealand
027 441 4309
[email address] Transporting New Zealand, PO Box 1778, Wellington 6140, Level 3, 93 Boulcott Street, Wellington, 6011.
Telephone: (04) 472 3877, Email
: [email address], Website: www.transporting.nz
4

Document 20
Out of Scope
From: Aimee Wiley <[email address]>
Sent: Tuesday, 3 June 2025 3:28 pm
To: Katrina Quickenden <[email address]>
Cc: Jacob Ennis <[email address]>; Laura Bender <[email address]>; Paul O'Connell
<P.O'[email address]>; Mike Hargreaves <[email address]>; Amy Moorhead
<[email address]>; Brent Alderton <[email address]>
Subject: MIA Submission - Draft transport rules reform work programme
Kia ora Katrina,
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Further to my note last week, please find attached the MIA’s formal feedback on the draft transport rules
reform work programme.
This is a significant and timely reform for our industry. We’ve taken care to prepare a considered and detailed
response that clearly outlines the real-world challenges our members are facing, the regulatory barriers
currently impeding progress, and the solutions we believe are needed to ensure the reform achieves its
intended impact.
We’ve approached this with the seriousness and urgency it warrants and with a view to ensuring the final
programme is both practical and transformative.
We hope our contribution adds value to the next stage of your advice to the Minister.
INFORMATION
As always, I’m happy to meet/discuss any aspect further, please don’t hesitate to get in touch to arrange a
suitable time if/when you are ready to discuss further.
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Ngā mihi,
Aimee Wiley
Chief Executive O icer, Motor Industry Association
OFFICIAL
From: Katrina Quickenden <[email address]>
Sent: Thursday, 10 April 2025 4:54 pm
To: Greig Epps <[email address]>; Justin Tighe-Umbers <[email address]>; Dom
Kalasih <[email address]>; [email address]; Lee Marshall <[email address]>;
1
Duplicate of email dated 10 April 2025 from Katrina Q
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s 9(2)(a)
INFORMATION
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Motor Industry Association (MIA)
Submission on the Draft Land Transport Rules Reform
April 2025
Submitted to:
Ministry of Transport Te Manatū Waka
Attention: Katrina Quickenden and Paul O’Connell
By email: [email address]; P.O'[email address]
New Zealand Transport Agency Waka Kotahi
Attention: Amy Moorehead, Brent Alderton and Mike Hargreaves
By email: [email address]; [email address]; [email address]
Prepared by:
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Aimee Wiley
Chief Executive O icer
Motor Industry Association of New Zealand
Wellington, Aotearoa New Zealand
Purpose of this Submission:
This submission provides the Motor Industry Association’s detailed feedback on the Draft Rules Reform Work
Programme. It sets out:
A comprehensive summary of regulatory barriers currently faced by the new vehicle sector
Specific, evidence-based proposals for reform
Clear rationale and real-world examples drawn from MIA’s membership ba
INFORMATION se
Recommendations designed to support a modern, future-ready land transport system
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This submission reflects the depth of industry concern and the critical importance of getting this reform
programme right. Not only to remove unnecessary friction but to enable innovation, safety, and sustainability
in the New Zealand vehicle fleet.
OFFICIAL
Contact:
Aimee Wiley
Chief Executive
Email: [email address]
Phone: s 9(2)(a)
About the Submitter
The Motor Industry Association (MIA) is the peak body representing New Zealand's new vehicle industry. We are
an independent, apolitical, not-for-profit association comprising o icial importers and distributors of overseas
vehicle manufacturers (OEMs). Our 46 members, spanning 91 brands, account for over 98% of all new vehicles
sold in New Zealand, including passenger vehicles, light and heavy commercial vehicles, and motorcycles.
MIA members are committed to safety, environmental performance, and a robust regulatory framework that
supports the delivery of safe, clean, and technologically advanced vehicles to New Zealand roads.
Executive Summary
The Motor Industry Association welcomes the Ministry of Transport's Rule Reform as a timely opportunity to
address long-standing regulatory issues that are limiting industry progress and public benefit.
However, the current scope and timeframe of the proposed reforms are misaligned with the speed of
technological change, the scale of international regulatory shifts, and New Zealand's own ambitions for safety,
emissions reduction, and economic resilience.
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This submission identifies specific reforms that are:
Urgent: addressing rule misalignments and regulatory bottlenecks already constraining investment and
fleet transformation.
Practical: able to be implemented with minimal disruption and high impact across industry and
government.
Globally aligned: leveraging proven Australian and UNECE standards to eliminate duplication and
improve vehicle availability.
Forward-facing: enabling modern compliance methods, fair treatment of electrified vehicles, and
proactive safety technologies.
INFORMATION
Without accelerated reform, New Zealand risks falling further behind its international peers. With it, we can
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unlock significant transport, environmental, and economic gains. We urge the Ministry and Agency to bring
forward action on consensus items, embed global alignment as standard practice, and partner with industry on
co-designing practical, future-proofed rule frameworks.
OFFICIAL
Introduction
New Zealand's land transport rule framework is no longer fit for purpose. Regulatory delay and misalignment
are increasingly at odds with the pace of technological innovation, consumer expectations, and international
trade norms.
The MIA supports the Ministry's intent to modernise the system but urges a faster, broader, and more
coordinated approach. Current reliance on exemptions, manual workarounds, and disconnected processes is
undermining confidence and limiting public benefit.
This submission is built on direct industry input and lived experience, structured around the Ministry's reform
programme. It identifies high-value changes that:
1. Align with Australia's ADR and UNECE global standards.
2. Improve digital access to compliance and certification processes.
3. Enable electrified and safety-advanced vehicle uptake.
4. Reduce unnecessary administrative duplication.
Above all, the submission outlines how smarter, more globally aligned regulation can reduce the compliance
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burden, support investment certainty, and deliver better safety and environmental outcomes for all New
Zealanders.
Cross-Cutting Strategic Reform Themes
The issues raised in this submission are not isolated. They stem from five systemic challenges that, if
addressed, can elevate the performance, coherence, and credibility of the entire transport regulatory system:
1. Advance Critical Rule Reviews Now
Do not delay reform of the VDAM Rule and overhaul of the import requirements and vehicle
regulatory system until 2026–27. These rules underpin vehicle access, safety, and compliance.
INFORMATION
Early action is essential.
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2. Default to Global Equivalence
Make recognition of ADR and UNECE standards the default position. Avoid bespoke local
rulemaking unless there is a clear, evidence-based reason.
3. Digitise Core Regulatory Processes
Replace paper-based, fragmented compliance systems with digital, real-time tools that increase
OFFICIAL
transparency and reduce cost.
4. Adapt Rules to Enable Clean Technology
Update GVM thresholds, dimensional allowances, and safety feature recognition to reflect the
realities of modern vehicle design.
5. Reduce Reliance on Workarounds
Codify common, safe configurations and eliminate overuse of exemptions. Build certainty into the
rulebook, not around it.
Out of Scope
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INFORMATION
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2. Modernising and Digitising Transport Services and
Licensing
OFFICIAL
2.1 Digitise Vehicle Registration and Replace the MR2A
Problem
The current vehicle registration system is still reliant on paper-based processes, most notably the MR2A form.
This creates ine iciencies, inconsistencies across dealerships, delays in processing, and unnecessary
duplication - all of which are avoidable with modern digital infrastructure.
Examples
MR2As must be printed, physically signed, and manually submitted — even when digital versions exist.
Enforcement of scanned MR2A use varies by region and agent.
“We are repeatedly told to re-submit physical MR2As even after uploading digital versions. This adds
time, cost, and duplication.”
OEMs and dealers have no dashboard or interface to manage VINs, check registration status, or track
compliance in real time.”
Proposed Solutions
Fully digitise the registration process and retire the MR2A form.
Integrate MIAMI and LanData data to pre-fill VIN, emissions, and model attributes.
Provide a live, centralised dashboard for dealers, distributors, and OEMs to manage vehicle registration
and compliance.
Rationale
Streamlining registration improves e iciency, reduces form errors, enables faster delivery, and aligns transport
services with broader public sector digital transformation. Transparency and compliance improve at every
level.
2.2 Enable Industry Access to Manage VIN and Model Data
Problem
Importers, OEMs, and vehicle distributors are unable to manage their own VIN, model, or chassis data in real
time. This centralised restriction causes unnecessary delays, errors, and creates ine iciencies for both
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regulators and industry.
Examples
No platform exists to check Pre-Delivery Inspection (PDI) status, confirm VIN credit eligibility, or track
pending liabilities.
Vehicles exported after arrival remain visible in the Clean Car Standard (CCS) system, inflating liability
calculations.
“We can’t easily tell which VINs are fully cleared and which are still pending CCS - this a ects how we
plan fleet purchasing.”
Stakeholders have requested anonymised visibility of credit flows by market segment to support fair
procurement and pricing strategies.
INFORMATION
Proposed Solutions
Develop secure, role-based dashboards allowing approved users to view VIN cr
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and emissions liabilities.
Enable bulk removal of exported vehicles from CCS tracking.
Provide anonymised, aggregated CCS credit flow data by segment to support commercial decision-
making.
Rationale
OFFICIAL
Access to live, accurate data will increase confidence in the CCS system, reduce administrative overhead, and
support industry in achieving both regulatory compliance and carbon reduction targets.
9. Conclusion and Strategic Recommendations
New Zealand’s land transport rules must evolve to remain fit for purpose in a rapidly changing global
landscape. This submission sets out a practical, evidence-based plan to improve the system’s e ectiveness,
responsiveness, and credibility.
The Motor Industry Association recommends that the Ministry and Agency together:
1. Accelerate Priority Reforms
Advance early action on high-impact areas such as axle weight harmonisation, MR2A digitisation, and pro-
forma streamlining.
2. Address Known System Gaps
Target reforms to legacy rule components that are driving unnecessary exemptions or delays—particularly
VDAM, LVVTA certification, and Annex C processing.
3. Mandate Global Alignment
Implement mutual recognition of ADR and UNECE standards as a default compliance pathway across key
certification and design domains.
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4. Invest in Digital Transformation
Modernise compliance tools and rule access through digital dashboards, real-time vehicle tracking, and
machine-readable rulebooks.
5. Formalise Industry Co-Design
Establish structured pathways for industry-government col aboration on rule development, test validation,
and transitional guidance.
These reforms are not speculative. They are operationally grounded, internationally aligned, and supported by
industry consensus. Their implementation will reduce regulatory churn, improve safety and emissions
outcomes, and restore New Zealand’s standing as a modern, high-integrity vehicle market.
INFORMATION
We urge the Ministry and Agency to act with pace and purpose. The policy foundations are in place. The sector
is aligned. What’s needed now is implementation leadership.
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OFFICIAL

Document 21
Neha Pawar
From:
Katrina Quickenden
Sent:
Thursday, 17 July 2025 5:54 pm
To:
Amy Moorhead; Dom Kalasih; Greig Epps; Aimee Wiley; David Boyce; Terence J.
Collins (AA); James Smith; Chris Rodley; Laura Bender; Keegan Taylor; Ryan
McGowan
Cc:
Mike Hargreaves; James McDowall
Subject:
RE: Transport sector/NZTA/MoT stakeholder meeting: notes and actions from 15
July meeting
Attachments:
Rules Reform Prog summary for sector stakeholders July 2025 to share.pptx
Kia ora koutou
Please find attached a slightly updated version of our slides – we took the opportunity to clarify a few
points that we discussed yesterday. We are happy for you to use this information with your members.
Kind regards,
Katrina
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Katrina Quickenden
Manager - Regulatory Reform Team | Kaiwhakahaere
Te Manatū Waka Ministry of Transport
M s 9(2)(a)
E: [email address] | transport.govt.nz
Out of scope
INFORMATION
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OFFICIAL
1

Land Transport Rules Re
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form
Programme
Overview and next stepsINFORMATION
15 July 2025
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OFFICIAL
Overview
• Problems and objectives
• Programme overview
• Programme timelines
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• Workstream updates
• Next steps
INFORMATION
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OFFICIAL
The issues you’ve raised have informed the programme’s objectives
Regulation not always
Barriers to new/
targeting the right
emerging technology
System is old and hard
to change
Problems and
things
(eg heavy EVs)
opportunities:
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Unneccessary costs for
Inhibits freight
Import req'ts falling
Inhibits access to
Effort wasted managing Services not always easy
users and the sector
productivity
behind int'l standards,
affordable, low-
trade obligations
emissions vehicles
by exception
for users to access/use
INFORMATION
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Improve the safety
Improve consumer
A more adaptable
Digitise and
Objectives:
Reduce regulatory
Increase heavy
compliance costs
vehicle productivity
and quality of our
choice in the vehicle
and enabling
modernise
vehicle fleet
market
regulatory system
government services
OFFICIAL
We have seven workstreams to help achieve the objectives
Objectives:
Reduce
Increase Heavy
Improve safety
Improve
A more adaptable Digitise and
regulatory
vehicle
and fleet quality
consumer choice
and enabling
modernise
compliance costs
productivity
in the vehicle
regulatory system government
market
services
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Workstreams: 1) Reduce WOF/COF 4a) Review freight
2) Consider further
7) Overhaul the vehicle regulatory system
5) Enable a digital
frequency for
permitting
safety requirements
driver licence, digital
vintage/veteran
requirements
for vehicle imports
documents, and e-
vehicles and private
servicing
heavy motorhomes
4b) Review weight
thresholds for Class 1
and Class 2 licences
3) Review WOF/COF
frequency and
4c) Simplify heavy
INFORMATION
inspection
vehicle driver
requirements for light licencing (consulted
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vehicles
on in 2019)
4d)VDAM review
6) Improve lane use
(longer-term work
and use of traffic
progressing in parallel
control devices, and
to the above work on
OFFICIAL
minor system
other possible
improvements
changes to VDAM
and other rules)
There will be a series of opportunities for public consultation
Each box below goes from when we expect consultation to start, to when we expect rules to be signed for each
change.
Though consultation is staged, the policy work is happening in paral el, and has already begun
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
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1) Reduce vintage/motorhome
WOF/COF frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light
vehicles
4a) Review freight permitting requirements
4b) Review licence weight thresholds
INFORMATION
5) Enable a digital driver licence, digital
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Notes:
6) Improve lane use and use of traffic control
• For 4c) Simplify heavy vehicle driver licencing (proposals
devices
consulted on in 2019), we are considering whether further
consultation is required – timelines TBC OFFICIAL
7) Overhaul the system
• For 4d) VDAM review, research and analysis are being
commissioned to inform policy development
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reduce vintage/motorhome WOF/COF
frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light vehicles
4a) Review freight permitting requirements 4b) Review licence weight thresholds
5) Enable a digital driver licence, digital documents, and
e-servicing
6) Improve lane use and use of traffic control devices
7) Overhaul the system
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Vintage/motorhome WOF/COFs
• Consultation is complete, with strong support for
the proposals
• The Minister is considering final advice on the
proposals
INFORMATION
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OFFICIAL
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reduce vintage/motorhome WOF/COF
frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light vehicles
4a) Review freight permitting requirements 4b) Review licence weight thresholds
5) Enable a digital driver licence, digital documents, and
e-servicing
6) Improve lane use and use of traffic control devices
7) Overhaul the system
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Mandating safety features
• Did some targeted engagement earlier in the year with
stakeholders
• Working on further data and analysis
• Working toward open-ended consultation on multiple options
INFORMATION
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Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reduce vintage/motorhome WOF/COF
frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light vehicles
4a) Review freight permitting requirements 4b) Review licence weight thresholds
5) Enable a digital driver licence, digital documents, and
e-servicing
6) Improve lane use and use of traffic control devices
7) Overhaul the system
ACT 1982
Light vehicle WOFs and COFs
• Developing and analysing options for:
• Changes to inspection frequency
• Checking increasingly common
technologies/features that are not currently in scope
• Rationalising which light vehicles require a COF vs a
WOF
INFORMATION
RELEASED UNDER THE
OFFICIAL
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reduce vintage/motorhome WOF/COF
frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light vehicles
4a) Review freight permitting requirements 4b) Review licence weight thresholds
5) Enable a digital driver licence, digital documents, and
e-servicing
6) Improve lane use and use of traffic control devices
7) Overhaul the system
ACT 1982
Heavy vehicle productivity
• Considering timing and process for 2019 proposals
Timing TBC
on simplifying heavy vehicle licencing – e.g. whether
4c) Simplify heavy
any updates or further consultation are required
vehicle driver
licencing (consulted
• Scoping and policy development for freight
on in 2019)
permitting and licence weight thresholds work
(including NZTA engagement with Road Transport
4d)VDAM review
Policy Group)
(longer-term work
INFORMATION
progressing in parallel
• Commissioning research and analysis to inform
RELEASED UNDER THE
to the above work on
longer-term VDAM review (impact of bigger, heavier
other possible
vehicles on roads)
changes to VDAM
and other rules)
OFFICIAL
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reduce vintage/motorhome WOF/COF
frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light vehicles
4a) Review freight permitting requirements 4b) Review licence weight thresholds
5) Enable a digital driver licence, digital documents, and
e-servicing
6) Improve lane use and use of traffic control devices
7) Overhaul the system
ACT 1982
Enabling digitisation
• Progressing enabling changes to primary
legislation
• Scoping and planning required rule changes
Lane use and traffic control
INFORMATION
• Scoping and planning policy workRELEASED UNDER THE
OFFICIAL
Apr – Jun 2025
Jul – Sep 2025
Oct – Dec 2025
Jan – Mar 2026
Apr – Jun 2026
1) Reduce vintage/motorhome WOF/COF
frequency
2) Consider further safety requirements for imports
3) Review WOF/COF inspection requirements and frequency for light vehicles
4a) Review freight permitting requirements 4b) Review licence weight thresholds
5) Enable a digital driver licence, digital documents, and
e-servicing
6) Improve lane use and use of traffic control devices
7) Overhaul the system
ACT 1982
System overhaul
• Scoping initial work on:
• Simplified entry for vehicles subject to type
approvals overseas
• Streamlining recognition of international INFORMATION
standards
RELEASED UNDER THE
OFFICIAL
Next steps
• Continuing to progress policy work
• Ongoing planning, including identifying any
points where targeted stakeholder
ACT 1982
engagement is needed
• Briefing ministers prior to next wave of public
consultation (due to begin in October)
INFORMATION
RELEASED UNDER THE
OFFICIAL

ACT 1982
INFORMATION
RELEASED UNDER THE
OFFICIAL
Document Outline
- _OC251092 Combined_Redacted
- Relevant interagency consultation - June 2025 LEG Cabinet paper and draft Bill - RSTA Bill.pdf
- Relevant interagency consultation - June 2025 ECO Cabinet paper - Rules Reform.pdf
- OC251092 Drummond response_Part3.pdf
- _OC251092 Combined_Redacted
- External Consultation.pdf