29 April 2026
45 Pipitea Street, Wel ington 6011
Phone +64 4 495 7200
dia.govt.nz
P Peach
fyi-request-34263
[email address]
Tēnā koe P Peach
OIA request 2526-1035 - Request for information about NAATI credential compliance and
subcontracting practices in DIA translation and interpreting services
Thank you for your Official Information Act (Act) request received by the Department of Internal
Affairs (Department) on 27 March 2026.
You requested –
SECTION A: SUBCONTRACTING ARRANGEMENTS
1.
Whether DIA's Translation Service or any external translation or interpreting
providers contracted to DIA are permitted to subcontract assignments to third
parties, including overseas-based agencies or individual contractors located outside
New Zealand.
2.
Any conditions or restrictions in DIA's contracts with translation or interpreting
providers regarding the use of subcontractors, including any requirements that
subcontractors be based in New Zealand or hold an appropriate New Zealand work
visa.
3.
Whether DIA requires providers to disclose the identity, location, or credentials of
individual translators or interpreters — including subcontractors — who carry out
assignments on DIA's behalf.
4.
Whether DIA has any knowledge of, or has sought information about, assignments
being routed to interpreters or translators located outside New Zealand.
5.
Any instances where DIA became aware that an assignment was conducted by a
person located outside New Zealand or by an uncredential ed subcontractor, and any
action taken as a result.
SECTION B: NAATI CREDENTIAL COMPLIANCE
6.
What mechanism, if any, DIA uses to verify that individual translators and
interpreters carrying out assignments on its behalf — including those engaged
through subcontracting arrangements — hold a valid NAATI credential or Working
Towards NAATI (WTN) status.
7.
Whether DIA requires its translation or interpreting providers to maintain and supply
a current register of credential ed practitioners working under DIA contracts, and if
so whether DIA has received and reviewed such registers.
8.
Any audits, spot checks, or compliance reviews conducted by DIA on its translation or
interpreting providers since 1 July 2024 to verify NAATI credential compliance,
including the methodology and findings of any such reviews.
9.
Any instances since 1 July 2024 where a provider was found to have used a translator
or interpreter who did not hold the required NAATI credential or Working Towards
NAATI (WTN) status, and any consequences or remedial action taken.
10. Any complaints received by DIA since 1 July 2024 from staff, clients, or members of
the public regarding the qualifications or conduct of a translator or interpreter
engaged through DIA's services.
SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY
11. Whether DIA has any information about the rates or fees paid by its external
providers to individual translators or interpreters for assignments conducted on DIA's
behalf.
12. Whether DIA has ever sought, as part of contract negotiations, tendering processes,
or performance reviews, any information about the pay or working conditions of
translators or interpreters engaged through its provider contracts.
13. Any internal policies, briefings, risk assessments, or correspondence within DIA
regarding the fair remuneration or employment conditions of translators and
interpreters working under its contracts, including any concerns raised about the
margin between rates paid to providers and rates passed on to practitioners.
Whether DIA's tendering or procurement criteria for translation and interpreting services include
any consideration of whether providers pay practitioners at or above a minimum rate, living
wage, or industry standard.
In response to your request I can provide you with the fol owing information.
SECTION A: SUBCONTRACTING ARRANGEMENTS
Question one
The Department’s Translation Service (TTS) works with translators based in New Zealand and
abroad. Those translators are not permitted to subcontract translation work assigned to them.
The Department utilises the Language Assistance Services (LAS) panel of providers for
interpreting services, specifical y Connecting Now and Interpreting New Zealand. This is made
available to us through the syndicated contracts titled “Open Syndicated Panel Agreement for
Face-to-Face Interpreting Services” and “Open Syndicated Panel Agreement for Telephone and
Video Interpreting Services”. These open syndicated contracts (OSCs) operate as national
models that enable agencies to access interpreting services efficiently and effectively across
New Zealand. As a customer, DIA does not monitor LAS compliance for the interpreting services
and does not hold the details requested. Therefore, I am refusing this part of your request
under section 18(e) of the Act, as the documents al eged to contain the information requested
do not exist or, despite reasonable efforts to locate them, cannot be found.
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Question two
I refer to my response to question one. As TTS does not al ow translators to subcontract, there
are no other applicable requirements for subcontractors.
The Department does not manage the OSCs relating to interpreting services. I recommend that
you contact the Ministry of Ethnic Communities if you would like more information about the
use of sub-contractors, if any.
Question three
For translators, the details relating to identity, location or credentials are col ected during the
induction process when a translator is first engaged by TTS.
The Department does not require interpreting providers to disclose details relating to identity,
location or credentials of interpreters. This is covered by the OSCs with specified providers.
Question four
The majority of TTS’ translation work is carried out by translators based in New Zealand.
However, translation work is routinely commissioned to translators located outside New
Zealand.
The location of interpreters employed through the OSCs is managed by the Ministry of Business,
Innovation & Employment (MBIE). Therefore, the Department does not hold this information. I
refuse this part of your request under section 18(e) of the Act.
Question five
I have interpreted this question as applying only to TTS, as you have not referred to interpreters.
Where TTS’ work is commissioned to translators located outside New Zealand, TTS does not
require translators to comply with National Accreditation Authority for Translators and
Interpreters (NAATI). Therefore, it isn’t necessary for TTS to take any fol ow up action.
SECTION B: NAATI CREDENTIAL COMPLIANCE
Question six
As advised above, TTS’ translators are not required to comply with NAATI. Where this
certification is claimed as part of a translator’s application, NAATI credentials have been verified
via the online directory of NAATI translators. The directory can be found at
https://directory.naati.com.au/.
For interpreters, MBIE manages NAATI credentials under the OSCs. Therefore, the Department
does not use any mechanism to verify NAATI compliance. For further information please contact
MBIE.
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Question seven
The Department does not require its translation or interpreting service providers to maintain or
provide the Department with a register of credential ed practitioners. As a result, the
Department has not received or reviewed any such registers.
Question eight
I can advise that NAATI credential ing is not a requirement for translators, therefore, the
Department has not undertaken any audits, spot checks, or compliance reviews since 1 July
2024 to verify NAATI credential compliance.
Similarly, no such work has occurred in respect of the Department’s use of Connecting Now and
Interpreting New Zealand.
Question nine
I can advise that no remedial action has been taken against translators without NAATI
credentials.
For interpreters, the OSCs are managed by MBIE and if you require further information we
recommend that you contact them directly.
Question ten
The Department has not received any complaints since 1 July 2024 from staff, clients or
members of the public regarding the qualifications or conduct of a translator or LAS panel
interpreter engaged by the Department.
SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY
For questions 11 to 14, I do not hold the requested information for interpreting services and I
refuse these questions under section 18(e). I recommend that you contact MBIE and MEC for
information about interpreting services used by the Department through the OSCs. However,
we specifical y reply to these questions for TTS.
Question eleven
Most translation work is carried out by individuals contracted directly to TTS. TTS does not have
oversight or information on the pay rates offered by external Language Service Providers (LSPs)
to the translators they work with.
Question twelve
TTS has not sought information of the internal processes of LSPs that have been engaged to
provide translation services. This includes pay and working conditions.
Page 4 of 5
Question Thirteen
The Department does not hold any internal policies, briefings, risk assessments, or
correspondence relating to the fair remuneration or employment conditions of translators
working for TTS, including any concerns about the margin between rates paid to providers and
rates passed on to individual practitioners. Therefore, I refuse this part of your request under
section 18(e) of the Act.
Question fourteen
The pay rates for translation services offered by TTS take into account the minimum rates, living
wage and industry standards for translation services.
Proactive Release
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.
Access to the Ombudsman
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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