Citizenship by Grant English language requirement clarification and process
David Singh made this Official Information request to Department of Internal Affairs
The request was partially successful.
From: David Singh
Dear Department of Internal Affairs,
I have a few questions regarding English language requirements for Citizenship by Grant (CBG) applications. I am seeking clarification at a general policy and practice level.
1. English language test requirements
If an applicant uses an English language test to demonstrate knowledge of the English language, what are the minimum acceptable scores for:
- IELTS (overall score and minimum component scores)?
- Other accepted tests such as TOEFL or PTE, if applicable?
2. Interview process and progression to the next decision stage
When the case officer has questions regarding the applicant's English ability, I would like to clarify whether the interview process must be completed in full before the application can progress to English Waiver assessment or Ministerial consideration.
In particular:
- Is the second interview (after a further six months) mandatory in all cases, or can an application proceed to the next decision stage without completing the second interview?
- Can an applicant choose to decline the second interview in order to avoid delay and proceed directly to English Waiver assessment?
- Is there any flexibility to accelerate the process in cases where it is evident that the English language requirement will not be met, rather than requiring the applicant to wait the full six-month period?
3. Age-related impairment under the English Language Waiver Schedule
I would like to understand how age-related impairment is assessed in practice under the English Language Waiver Schedule. Specifically:
- Can age alone be sufficient to establish age-related impairment for the purpose of an English language waiver?
- If age alone can be sufficient, is there an indicative age at which applicants may be considered unable to meet the English language requirement due to age-related impairment?
- If age alone is not sufficient, what additional factors are typically considered (for example, cognitive decline, learning capacity, or other age-related limitations)?
- Is medical or professional evidence, such as a doctor’s assessment, generally required to support a claim of age-related impairment?
4. Other personal factors relevant to an English language waiver
What other “personal factors” are commonly taken into account when assessing whether an applicant may be included on an English Language Waiver Schedule?
5. Ministerial consideration where English language requirements are not met
Where an applicant does not meet the English language requirement and does not clearly meet the criteria for inclusion on an English Language Waiver Schedule, what key factors are typically considered when the case is submitted to the Minister?
In particular, what circumstances may lead to citizenship being granted under section 8(8), as opposed to the application not being approved?
6. Process guidance / decision framework
Please provide any flowchart, standard operating procedure (SOP), or other process guidance that outlines, step by step, showing how it is determined whether an applicant meets the English language requirement?
In particular, any guidance showing how a case officer considers factors such as the applicant’s age, education background, employment, and circumstances in which concerns about English language ability may arise, as well as how decisions are made regarding English Language Waivers and Ministerial submissions.
7. Statistical information for applications with an outcome
Please provide aggregated data for the period 2020–2025 relating to Citizenship by Grant (CBG) applications where an applicant’s English language ability required further assessment.
For each outcome year, please provide data in total and broken down by the following age groups:
- 60–64 (inclusive);
- 65–69 (inclusive); and
- 70 and over.
Specifically, could you please provide:
- The number of applicants who were required to attend at least one English language interview due to concerns that they may not meet the English language requirement;
- Of these applicants, the number who were assessed as not clearly meeting the English language requirement and were referred to the English Language Waiver Schedule;
- Of those referred to the English Language Waiver Schedule, the number who met the requirements and were subsequently approved for citizenship under the Waiver Schedule;
- Of applicants who did not clearly meet the requirements to be included on the English Language Waiver Schedule and were referred to the Minister as a submission, the number who were granted citizenship following Ministerial consideration under section 8(8); and
- The number of applicants who were not approved following Ministerial consideration, due to not meeting the English language requirement.
Yours faithfully,
David Singh
From: OIA
Department of Internal Affairs
Tçnâ koe,
Thank you for contacting the Department of Internal Affairs. You have
contacted us during the annual legislative closedown period of public
service OIA processing, which spans 24 December 2024 to 15 January 2025
(inclusive).
During this period public service Official Information Act processing is
suspended.
If you are making a new Official Information Act (OIA) request for
information held by the Department, we will respond to you after OIA
processing resumes on Thursday the 16th January 2025. You can check the
time limit for the Department’s response in the [1]Ombudsman’s OIA
Response Calculator.
If you are contacting the Department about information that is held by a
different agency; a Minister; or a Local Authority, you will receive your
answer up to two weeks sooner if you [2]request the information from them
directly. If you will be contacting them directly, please take a moment
to let us know that you are withdrawing your request to the Department.
Nâku noa, nâ
Privacy and Official Correspondence team
Legal Services | Enterprise Services
Level 6, 45 Pipitea St | PO Box 805, Wellington 6140, New Zealand |
[3]www.dia.govt.nz
References
Visible links
1. http://www.ombudsman.parliament.nz/
2. https://www.govt.nz/organisations/mail-m...
3. http://www.dia.govt.nz/
From: David Singh
Dear Department of Internal Affairs,
Please also provide a copy of the current policy used by the Department when assessing the
English language of an CBG applicant.
Yours faithfully,
David Singh
From: RIS Official Correspondence
Department of Internal Affairs
Kia ora David,
Thank you for your OIA request to the Department of Internal Affairs on
the 13^th and 14^th January 2026. The Department has also received another
request (as also seen below) on 29 January 2026, that is of similar nature
to your previous ones which we have decided to amalgamate together with
your original request.
As your additional request dated 29 January 2026, is treated as a new
request, this replaces the original as of the date of the amendment (in
accordance with section 15(1AA) of the Act). The timeframe for response
has been adjusted accordingly. The Department’s response will now be
provided as soon as practicable and by no later than 27 February 2026.
Please note that in cases where the Department’s response provides
information that is identified to be of general public interest, the
response may also be published on the Department of Internal Affairs
website. If the Department publishes its response to your OIA request,
all personal information, including your name and contact details, will be
removed.
Ngâ mihi
Michael Mahoney | Advisor| Kaitohutohu
Official Correspondence | Reta Ôkawa
Regulatory and Identity Services | Taituarâ
The Department of Internal Affairs | Te Tari Taiwhenua
[1]dia.govt.nz | [2]Facebook | [3]LinkedIn
[4]Logo: Internal Affairs — Te Tari Taiwhenua
-----Original Message-----
From: David Singh <[5][email address]>
Sent: Thursday, 29 January 2026 11:43 am
To: OIA <[6][DIA request email]>
Subject: Official Information request - Request a document - Guidelines
for English language assessment for CBG
[You don't often get email from
[7][email address]. Learn why this is
important at [8]https://aka.ms/LearnAboutSenderIdentific... ]
Dear Department of Internal Affairs,
I would like to request a latest version of a document entitled
"Guidelines – Assessing and recording English language ability for grant
of citizenship"
Yours faithfully,
David Singh
-----Original Message-----
From: David Singh <[9][FOI #33503 email]>
Sent: Wednesday, 14 January 2026 10:51 am
To: OIA <[10][DIA request email]>
Subject: Re: Official Information request - Citizenship by Grant English
language requirement clarification and process
[You don't often get email from
[11][FOI #33503 email]. Learn why this is
important at [12]https://aka.ms/LearnAboutSenderIdentific... ]
Dear Department of Internal Affairs,
Please also provide a copy of the current policy used by the Department
when assessing the English language of an CBG applicant.
Yours faithfully,
David Singh
-----Original Message-----
From: David Singh [13][FOI #33503 email]
Sent: Tuesday, 13 January 2026 11:55 pm
To: OIA [14][DIA request email]
Subject: Official Information request - Citizenship by Grant English
language requirement clarification and process
[You don't often get email from
[15][FOI #33503 email]. Learn why this is
important at [16]https://aka.ms/LearnAboutSenderIdentific... ]
Dear Department of Internal Affairs,
I have a few questions regarding English language requirements for
Citizenship by Grant (CBG) applications. I am seeking clarification at a
general policy and practice level.
1. English language test requirements
If an applicant uses an English language test to demonstrate knowledge of
the English language, what are the minimum acceptable scores for:
- IELTS (overall score and minimum component scores)?
- Other accepted tests such as TOEFL or PTE, if applicable?
2. Interview process and progression to the next decision stage
When the case officer has questions regarding the applicant's English
ability, I would like to clarify whether the interview process must be
completed in full before the application can progress to English Waiver
assessment or Ministerial consideration.
In particular:
- Is the second interview (after a further six months) mandatory in all
cases, or can an application proceed to the next decision stage without
completing the second interview?
- Can an applicant choose to decline the second interview in order to
avoid delay and proceed directly to English Waiver assessment?
- Is there any flexibility to accelerate the process in cases where it is
evident that the English language requirement will not be met, rather than
requiring the applicant to wait the full six-month period?
3. Age-related impairment under the English Language Waiver Schedule I
would like to understand how age-related impairment is assessed in
practice under the English Language Waiver Schedule. Specifically:
- Can age alone be sufficient to establish age-related impairment for the
purpose of an English language waiver?
- If age alone can be sufficient, is there an indicative age at which
applicants may be considered unable to meet the English language
requirement due to age-related impairment?
- If age alone is not sufficient, what additional factors are typically
considered (for example, cognitive decline, learning capacity, or other
age-related limitations)?
- Is medical or professional evidence, such as a doctor’s assessment,
generally required to support a claim of age-related impairment?
4. Other personal factors relevant to an English language waiver What
other “personal factors” are commonly taken into account when assessing
whether an applicant may be included on an English Language Waiver
Schedule?
5. Ministerial consideration where English language requirements are not
met Where an applicant does not meet the English language requirement and
does not clearly meet the criteria for inclusion on an English Language
Waiver Schedule, what key factors are typically considered when the case
is submitted to the Minister?
In particular, what circumstances may lead to citizenship being granted
under section 8(8), as opposed to the application not being approved?
6. Process guidance / decision framework Please provide any flowchart,
standard operating procedure (SOP), or other process guidance that
outlines, step by step, showing how it is determined whether an applicant
meets the English language requirement?
In particular, any guidance showing how a case officer considers factors
such as the applicant’s age, education background, employment, and
circumstances in which concerns about English language ability may arise,
as well as how decisions are made regarding English Language Waivers and
Ministerial submissions.
7. Statistical information for applications with an outcome Please provide
aggregated data for the period 2020–2025 relating to Citizenship by Grant
(CBG) applications where an applicant’s English language ability required
further assessment.
For each outcome year, please provide data in total and broken down by the
following age groups:
- 60–64 (inclusive);
- 65–69 (inclusive); and
- 70 and over.
Specifically, could you please provide:
- The number of applicants who were required to attend at least one
English language interview due to concerns that they may not meet the
English language requirement;
- Of these applicants, the number who were assessed as not clearly meeting
the English language requirement and were referred to the English Language
Waiver Schedule;
- Of those referred to the English Language Waiver Schedule, the number
who met the requirements and were subsequently approved for citizenship
under the Waiver Schedule;
- Of applicants who did not clearly meet the requirements to be included
on the English Language Waiver Schedule and were referred to the Minister
as a submission, the number who were granted citizenship following
Ministerial consideration under section 8(8); and
- The number of applicants who were not approved following Ministerial
consideration, due to not meeting the English language requirement.
Yours faithfully,
David Singh
-------------------------------------------------------------------
This is an Official Information request made via the FYI website.
Please use this email address for all replies to this request:
[17][FOI #33503 email]
Is [18][DIA request email] the wrong address for Official Information requests
to Department of Internal Affairs? If so, please contact us using this
form:
[19]https://aus01.safelinks.protection.outlo...
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[20]https://aus01.safelinks.protection.outlo...
If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.
-------------------------------------------------------------------
References
Visible links
1. https://www.dia.govt.nz/
2. https://www.facebook.com/dia.govt.nz
3. https://nz.linkedin.com/company/departme...
5. mailto:[email address]
6. mailto:[DIA request email]
7. mailto:[email address]
8. https://aka.ms/LearnAboutSenderIdentific...
9. mailto:[FOI #33503 email]
10. mailto:[DIA request email]
11. mailto:[FOI #33503 email]
12. https://aka.ms/LearnAboutSenderIdentific...
13. mailto:[FOI #33503 email]
14. mailto:[DIA request email]
15. mailto:[FOI #33503 email]
16. https://aka.ms/LearnAboutSenderIdentific...
17. mailto:[FOI #33503 email]
18. mailto:[DIA request email]
19. https://fyi.org.nz/change_request/new?bo...
20. https://fyi.org.nz/help/officers
hide quoted sections
From: RIS Official Correspondence
Department of Internal Affairs
Kia ora David,
Please find attached the response to your Official Information Act
Request.
Ngâ mihi
Michael Mahoney | Advisor| Kaitohutohu
Official Correspondence | Reta Ôkawa
Regulatory and Identity Services | Taituarâ
The Department of Internal Affairs | Te Tari Taiwhenua
[1]dia.govt.nz | [2]Facebook | [3]LinkedIn
[4]Logo: Internal Affairs — Te Tari Taiwhenua
References
Visible links
1. https://www.dia.govt.nz/
2. https://www.facebook.com/dia.govt.nz
3. https://nz.linkedin.com/company/departme...
From: David Singh
Dear RIS Official Correspondence,
Thanks for your earlier response.
Regarding the acceptable IELTS band scores, I just wanted to clarify one point. Is there any requirement around how recent the IELTS result must be when the CBG application is lodged? For example, does it need to have been obtained within the past three years, or would an older result still be acceptable?
Could you please confirm?
Yours sincerely,
David Singh
Things to do with this request
- Add an annotation (to help the requester or others)
- Download a zip file of all correspondence (note: this contains the same information already available above).

