27 February 2026
45 Pipitea Street, Wel ington 6011
Phone +64 4 495 7200
dia.govt.nz
David Singh
fyi-request-33503-
[email address]
Tēnā koe David
OIA request 25/26 0742 - Request for information about Citizenship by Grant English language
requirement
Thank you for your Official Information Act (Act) request received by the Department of Internal
Affairs (Department) on 1 January 2026.
You requested –
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 (overal 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 ful 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 al 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 wil not be met, rather than requiring the applicant
to wait the ful 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. Specifical y:
- 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 typical y considered (for
example, cognitive decline, learning capacity, or other age-related limitations)?
- Is medical or professional evidence, such as a doctor’s assessment, general y
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 typical y 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 wel 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 fol owing
age groups:
- 60–64 (inclusive);
- 65–69 (inclusive); and
- 70 and over.
Specifical y, 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;
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- 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 fol owing Ministerial
consideration under section 8(8); and
- The number of applicants who were not approved fol owing Ministerial
consideration, due to not meeting the English language requirement.
You also made the fol owing two requests -
On the 14 January 2026, you requested:
8. Please also provide a copy of the current policy used by the Department when
assessing the English language of an CBG applicant.
On the 29 January 2026, you requested:
9. I would like to request a latest version of a document entitled “Guidelines – Assessing
and recording English language ability for grant of citizenship”
On 11 February 20, the Department advised that due to the similar nature of your requests, that
they would be combined. You were also advised that your most recent request of 29 January
2029 replaces the original as of the date of the amendment (in accordance with section 15(1AA)
of the Act) and the requests would be responded to as soon as reasonably possible, and no later
than 27 February 2026.
In response to your requests, I can provide you with the fol owing information.
Attached to this letter are the relevant Appendices referenced throughout this response.
I note that some information may be withheld under section 9(2)(g)(i ) of the Act, as it is
necessary to maintain the effective conduct of public affairs through the protection of such
Ministers, members of organisations, officers, and employees from improper pressure or
harassment.
Under section 9(1) of the Act, I have considered if the reason for withholding the information
are outweighed by other considerations which render it desirable, in the public interest, to
make that information available. I have not identified any public interest that outweighs the
need to withhold the information.
I note, under section 8 of the Citizenship Act 1977 (Citizenship Act), citizenship by grant (CBG)
applicants must have sufficient knowledge of the English language. This is cal ed the ‘English
language requirement’. In practice, applicants must be able to use English to manage
independently in everyday situations. This could include:
talking with their doctor
getting help from salespeople
discussing their family and day-to-day life.
Where an applicant has indicated they do not speak English, but other evidence suggests they
may meet the requirement, a Life and Identity Services Officers (LISO) may use their
professional judgement to determine whether the applicant satisfies the English language
requirement.
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I also note that under section 8(8) of the Act1 the Minister may waive the English language
requirement if the applicant can prove that complying with the English requirement would
cause them to suffer undue hardship.
The Minister has pre-approved four criteria where it is considered an applicant would suffer
undue hardship if required to meet the English language requirement. These are:
1. Age-related impairment
2. Tried to learn and low levels of education/literacy in native tongue
3. Medical conditions; and
4. Tried to learn and other factors personal to the applicant
Questions one and nine
I refer you to Appendix A ‘Guidelines – Applying the English language requirement for
citizenship by grant’. These guidelines help a LISO determine if an applicant meets the English
language requirement for CBG. I note, this document has been updated and renamed from the
previous title of ‘Guidelines – Assessing and recording English language’.
I can advise that the Department may accept an International English Language Testing System
(IELTS) certificate where the overal band score is five or higher (Modest user-Expert user). A
band score of four (Limited user), may be accepted with other evidence or a phone cal to the
applicant where the applicant demonstrates an ability to converse in English. A band score of
three or lower (Extremely limited user-Nonuser) requires more evidence to satisfy the
requirement.
The Department does not use other testing systems such as Test of English as a Foreign
Language (TOEFL) or Pearson Test of English (PTE) however; an applicant may provide other
evidence such as other qualification certificates of English language ability as indicated in the
‘Guidelines’ at Appendix X to meet the English language requirement.
Questions two and eight
I refer you to Appendix B ‘Policy – English language requirement for citizenship by grant’. This
policy outlines the English language requirement in the Citizenship Act for CBG, including details
about the interview process.
I can advise that an English language interview is the only way to determine that an applicant
does not have sufficient knowledge of the English language. An applicant may be referred for an
English interview only after al other options to assess an applicant’s English ability has been
undertaken.
1 Citizenship Act 1977 No 61 (as at 18 September 2025), Public Act – New Zealand Legislation
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Applicants who attend an English language interview and do not have sufficient knowledge of
the English language may attend second and final interview in six months’ time or proceed with
the application seeking a waiver of the English language requirement, or as a submission to the
Minister, rather than wait to be interviewed again. They also have the choice to withdraw their
application and receive a partial refund, and re-apply when they feel they can meet the
requirement.
I also refer you to the current New Zealand citizenship guidance document2. This guidance
reflects the Minister of Internal Affairs’ current policy. It is intended to support transparency
and guide applicants, officials and the Minister in decision-making on citizenship applications.
Question three and four
I refer you to Appendix C ‘Policy – English language waiver schedule’. This policy outlines the
criteria for an applicant to be included on the English language waiver schedule, including
details about age-related impairment.
I can advise that ‘age’ alone is not considered an impairment for the purposes of being assessed
for an English language waiver.
For an applicant to be placed on the English waiver schedule under ‘Age-related impairment’,
the applicant must have an age-related impairment that would result in significant difficulty in
learning English. This could include but is not limited to hearing and/or memory loss.
This policy also outlines examples of other factors that can be considered, which may mean the
applicant would clearly suffer undue hardship if required to learn sufficient English. This
includes:
Any English language interviews with the applicant.
Circumstances of the applicant's arrival in New Zealand.
Degree of first language literacy.
Details of English language training/courses.
Language(s) spoken and cultural background.
Minor medical conditions
Age-related impairments.
Opportunity to use English in everyday life.
Other demands of life. For example, work or family responsibilities
Prior exposure to English.
Any other relevant factors submitted.
2 Citizenship Guidance Document
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I also refer you to Appendix D ‘Guidelines – English language waivers’. These guidelines outline
the options for placing an applicant on the English language waiver schedule, and the evidence
required for each.
I can advise that medical or professional evidence is required to confirm the applicant has an
age-related impairment that significantly impacts their ability to take English classes and/or
learn and retain new information.
Question five
I refer you to Appendix E ‘Policy - Grant of citizenship by reason of exceptional circumstances
and public interest’. This policy outlines the relevant legislation and policy relating to the public
interest and exceptional circumstances’ requirement of the Act.
Section 9(1)(c) of the Act states that the Minister may authorise the grant of citizenship under
this section if, satisfied that granting a certificate of New Zealand citizenship to the applicant
would be in the public interest because of exceptional circumstances of a humanitarian or other
nature relating to the applicant.
It is not possible to pre-determine what constitutes ‘exceptional circumstances’. An assessment
must be made on a case-by-case basis, having regard to the applicant’s particular circumstances.
The fol owing considerations are examples that the Department may take into account when
making a recommendation to the Minister:
the applicant's humanitarian or other personal circumstances, such as arriving in New
Zealand as a refugee with limited education
the reason(s) why the applicant cannot meet a particular requirement
whether the applicant's humanitarian or other personal circumstances preclude him/her
from meeting that particular requirement, now and in the future and the effect this wil
have, in general, on his/her circumstances
the intent of the requirement(s) that the applicant doesn't meet
any reason(s) why the applicant needs the grant of New Zealand citizenship
whether there are any other avenues open to the applicant to pursue, other than the
grant of New Zealand citizenship, and
what control the applicant has over their current humanitarian or other personal
circumstances that have led them to apply for citizenship.
The Minister must also be satisfied that, due to the applicant’s exceptional circumstances, it
would be in the public interest to grant citizenship. The public interest factor should general y,
arise directly from the applicant’s exceptional circumstances, and provide some advantage, or
positive benefit to New Zealand.
Question six
I refer you to information provided for questions one to five and in Appendices A to E. I also
refer you to Appendix F - ‘Procedure – English eligibility criteria requires manual assessment’.
This procedure outlines the steps to be taken when the automated ‘English criteria check’
cannot determine an applicant meets the English language requirement.
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Question seven
I refer you to Appendix G – ‘Citizenship statistics’ for data for the period 2020–2025 relating to
Citizenship by Grant (CBG) applications where an applicant’s English language ability required
further assessment.
As this information may be of interest to other members of the public, the Department has
decided to proactively release a copy of this response on the DIA website. Al requestor data,
including your name and contact details, wil be removed prior to release. The released
response wil be made available here: https://www.dia.govt.nz/Official-Information-Act-
Requests-2.
You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at www.ombudsman.parliament.nz or
freephone 0800 802 602.
Nāku noa, nā
Julia Taylor
Director Branch Performance
Regulatory and Identity Services
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