NAATI credential compliance and subcontracting practices in MSD translation and interpreting services
P. Peach made this Official Information request to Ministry of Social Development
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From: P. Peach
Tēnā koutou,
I am requesting the following information under the Official Information Act 1982 relating to subcontracting practices and NAATI credential compliance within interpreting and translation services procured by the Ministry of Social Development (MSD).
SECTION A: SUBCONTRACTING ARRANGEMENTS
1. Whether MSD's interpreting and translation providers 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 MSD's contracts with interpreting and translation 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 MSD requires providers to disclose the identity, location, or credentials of individual interpreters or translators — including subcontractors — who carry out assignments on MSD's behalf.
4. Whether MSD has any knowledge of, or has sought information about, assignments being routed to interpreters or translators located outside New Zealand.
5. Any instances where MSD became aware that an assignment was conducted by a person located outside New Zealand or by an uncredentialled subcontractor, and any action taken as a result.
SECTION B: NAATI CREDENTIAL COMPLIANCE
6. What mechanism, if any, MSD uses to verify that individual interpreters and translators 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 MSD requires its interpreting and translation providers to maintain and supply a current register of credentialled practitioners working under MSD contracts, and if so whether MSD has received and reviewed such registers.
8. Any audits, spot checks, or compliance reviews conducted by MSD on its interpreting and translation 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 an interpreter or translator 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 MSD since 1 July 2024 from staff, clients, or members of the public regarding the qualifications or conduct of an interpreter or translator engaged through MSD's services.
SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY
11. Whether MSD has any information about the rates or fees paid by its providers to individual interpreters or translators for assignments conducted on MSD's behalf.
12. Whether MSD has ever sought, as part of contract negotiations, tendering processes, or performance reviews, any information about the pay or working conditions of interpreters or translators engaged through its provider contracts.
13. Any internal policies, briefings, risk assessments, or correspondence within MSD regarding the fair remuneration or employment conditions of interpreters and translators working under its contracts, including any concerns raised about the margin between rates paid to providers and rates passed on to practitioners.
14. Whether MSD's tendering or procurement criteria for interpreting and translation services include any consideration of whether providers pay practitioners at or above a minimum rate, living wage, or industry standard.
If any part of this request is refused, please:
- Identify the specific OIA provision relied upon for each withholding;
- Consider whether the public interest in transparency around publicly funded services and the fair treatment of workers outweighs any commercial sensitivity; and
- Release any information that can be made available in redacted or aggregated form.
I am happy to receive this information in electronic format.
Ngā mihi
From: OIA_Requests (MSD)
Ministry of Social Development
IN-CONFIDENCE
Tçnâ koe P Peach
Thank you for your email received 27 March 2026, under the Official Information Act 1982. Your request has been forwarded to the appropriate officials at National Office to respond.
The information you have requested may contain the names and contact details of our staff. Please let us know by 31 March 2026 whether you require these names and contact details. We will need to consult our staff before deciding whether we can release this information, and this will take a bit more time. If we do not hear from you, we will assume that you do not require staff names and contact details.
Ngâ manaakitanga,
Official Information Team | Ministerial and Executive Services
Ministry of Social Development
Our Purpose:
We help New Zealanders to help themselves to be safe, strong and independent
Ko ta mâtou he whakamana tangata kia tû haumaru, kia tû kaha, kia tû motuhake
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From: OIA_Requests (MSD)
Ministry of Social Development
IN-CONFIDENCE
Kia Ora P Peach
We refer to your below request made to the Ministry of Social Development
(the Ministry) under the Official Information Act 1982 (the Act).
Your request is broad in scope and is likely to be refused under section
18(f) of the Act as substantial manual collation would be required to
provide the information requested.
As such, we suggest that you refine your request to enable us to provide
the information you are seeking.
1. In relation to translation and interpreting services you mentioned,
does this request extend to Te Reo Māori translation and
interpretation services (such as NZSL).
2. Or is your request focussed on the translation and interpretation of
what could be considered ethnic languages (for example: Arabic,
French).
Please note that once you have refined your request, under section 15(1AA)
of the Official Information Act, the Ministry will treat your refined
request as a new request that replaces the original request. This restarts
the 20-working day response period. This is required to ensure that the
Ministry has enough time to process your request
If you do not refine your request, the Ministry will proceed with your
original request. Please note that this is likely to result in a refusal
of your original request.
Please confirm your refinement / clarification on or before 7 April 2026.
Ngā mihi
Official Information team | Ministerial and Executive Services
Ministry of Social Development
Our Purpose:
We help New Zealanders to be safe, strong and independent.
Manaaki Tangata, Manaaki Whānau.
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From: P. Peach
Thank you for your emails regarding my request of 27 March 2026.
I write to address both points raised.
Staff names and contact details:
I do not require the names or contact details of individual MSD staff members. These can be redacted from any documents released in response to my request.
Scope clarification:
My request extends to all spoken language interpreting and translation services procured by MSD, including community and ethnic languages (such as Arabic, Mandarin, Samoan, Hindi, and similar languages spoken by New Zealand’s migrant and refugee communities) and te reo Māori. It does not extend to New Zealand Sign Language services.
My request is otherwise unchanged. I am seeking information across all three sections as originally submitted - subcontracting arrangements, NAATI credential compliance, and interpreter and translator pay visibility.
In regards to section 18(f) concern:
I note the Ministry’s indication that my request may be refused under section 18(f) on the basis that substantial manual collation would be required. I wish to make the following observations.
First, I ask that the Ministry evaluate each of my 14 questions individually. Section 18(f) cannot be applied to refuse an entire request where only some questions may require substantial collation. The Ombudsman’s guidelines are clear that agencies must consider releasing the parts of a request that can be answered without substantial collation, even where other parts cannot. I ask that the Ministry release answers to each question it is able to answer and identify specifically, by question number, which questions it considers require substantial collation and why.
Second, I note that many of my questions are policy and process questions that require no collation of records at all - for example, whether MSD has a verification mechanism for NAATI credentials, whether providers are required to maintain registers of credentialled practitioners, and whether MSD’s procurement criteria include consideration of practitioner pay. These questions can be answered by a policy adviser from existing knowledge and should not engage section 18(f) at all.
Third, I note that information about contracted providers, expenditure, and service volumes is likely held in MSD’s financial management and contract management systems and should be retrievable without substantial manual collation.
Fourth, I note that section 18(f) is a discretionary ground for refusal. Even where collation may be substantial, the Ministry retains the ability to release information where the public interest warrants it. Given the significant public interest in accountability around publicly funded services and compliance with the NAATI credentialling requirements that came into force on 1 July 2024, I ask that the Ministry exercise its discretion in favour of release.
Finally, if the Ministry intends to refuse any part of this request, I ask that it provide written reasons specific to each question refused, so that I may consider whether to refer the matter to the Office of the Ombudsman.
I look forward to the Ministry’s response.
Yours sincerely,
P. Peach
From: OIA_Requests (MSD)
Ministry of Social Development
IN-CONFIDENCE
Tçnâ koe Peach P,
On 27 March 2026 you emailed the Ministry of Social Development (the Ministry) requesting, under the Official Information Act 1982, the below information:
We have transferred your request to Ministry for Ethnic Communities (MEC) as the information to which your request relates is held by MEC. MEC is the Lead Agency for both the Face-to-face interpreting services and Telephone and video interpreting services Syndicated (All-of-Government) contracts, which are how the Ministry engages these services. The Lead Agency is responsible for all aspects of managing the Syndicated contracts. In these circumstances, we are required by section 14 of the OIA to transfer your request.
Please note that according to sections 14 and 15(1) of the Official Information Act, the 20-working day response period is reset by the transfer and starts again on the day MEC receives the transfer notification. The Ministry notified MEC of the transfer today.
You will hear further from MEC concerning your request in due course.
Nâ mâtou noa, nâ
Official Information Team | Ministerial and Executive Services
Ministry of Social Development
Our Purpose:
We help New Zealanders to be safe, strong and independent Manaaki Tangata, Manaaki Whânau
From: P. Peach <[FOI #34264 email]>
Sent: Friday, 27 March 2026 11:08 am
To: OIA_Requests (MSD) <[MSD request email]>
Subject: Official Information request - NAATI credential compliance and subcontracting practices in MSD translation and interpreting services
[You don't often get email from [FOI #34264 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]
Tçnâ koutou,
I am requesting the following information under the Official Information Act 1982 relating to subcontracting practices and NAATI credential compliance within interpreting and translation services procured by the Ministry of Social Development (MSD).
SECTION A: SUBCONTRACTING ARRANGEMENTS
1. Whether MSD's interpreting and translation providers 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 MSD's contracts with interpreting and translation 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 MSD requires providers to disclose the identity, location, or credentials of individual interpreters or translators — including subcontractors — who carry out assignments on MSD's behalf.
4. Whether MSD has any knowledge of, or has sought information about, assignments being routed to interpreters or translators located outside New Zealand.
5. Any instances where MSD became aware that an assignment was conducted by a person located outside New Zealand or by an uncredentialled subcontractor, and any action taken as a result.
SECTION B: NAATI CREDENTIAL COMPLIANCE
6. What mechanism, if any, MSD uses to verify that individual interpreters and translators 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 MSD requires its interpreting and translation providers to maintain and supply a current register of credentialled practitioners working under MSD contracts, and if so whether MSD has received and reviewed such registers.
8. Any audits, spot checks, or compliance reviews conducted by MSD on its interpreting and translation 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 an interpreter or translator 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 MSD since 1 July 2024 from staff, clients, or members of the public regarding the qualifications or conduct of an interpreter or translator engaged through MSD's services.
SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY
11. Whether MSD has any information about the rates or fees paid by its providers to individual interpreters or translators for assignments conducted on MSD's behalf.
12. Whether MSD has ever sought, as part of contract negotiations, tendering processes, or performance reviews, any information about the pay or working conditions of interpreters or translators engaged through its provider contracts.
13. Any internal policies, briefings, risk assessments, or correspondence within MSD regarding the fair remuneration or employment conditions of interpreters and translators working under its contracts, including any concerns raised about the margin between rates paid to providers and rates passed on to practitioners.
14. Whether MSD's tendering or procurement criteria for interpreting and translation services include any consideration of whether providers pay practitioners at or above a minimum rate, living wage, or industry standard.
If any part of this request is refused, please:
- Identify the specific OIA provision relied upon for each withholding;
- Consider whether the public interest in transparency around publicly funded services and the fair treatment of workers outweighs any commercial sensitivity; and
- Release any information that can be made available in redacted or aggregated form.
I am happy to receive this information in electronic format.
Ngâ mihi
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