
29 April 2026
P. Peach
[FYI request #34280 email]
Kia ora P. Peach
Transfer of request for official information, reference: GOV-047109 Thank you for your email of 28 March 2026, asking for the fol owing information under the Official
Information Act 1982 (the Act):
I am requesting the fol owing information under the Official Information Act 1982 relating to
subcontracting practices and NAATI credential compliance within interpreting and translation services
procured by the Accident Compensation Corporation (ACC / Te Kaporeihana Āwhina Hunga Whara).
SECTION A: SUBCONTRACTING ARRANGEMENTS
1. Whether ACC'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 ACC'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 ACC requires providers to disclose the identity, location, or credentials of individual
interpreters or translators — including subcontractors — who carry out assignments on ACC's behalf.
4. Whether ACC has any knowledge of, or has sought information about, assignments being routed to
interpreters or translators located outside New Zealand.
5. Any instances where ACC 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, ACC 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 ACC requires its interpreting and translation providers to maintain and supply a current
register of credential ed practitioners working under ACC contracts, and if so whether ACC has
received and reviewed such registers.
8. Any audits, spot checks, or compliance reviews conducted by ACC 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.
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10. Any complaints received by ACC since 1 July 2024 from staff, claimants, or members of the public
regarding the qualifications or conduct of an interpreter or translator engaged through ACC's services.
SECTION C: INTERPRETER AND TRANSLATOR PAY VISIBILITY
11. Whether ACC has any information about the rates or fees paid by its providers to individual
interpreters or translators for assignments conducted on ACC's behalf.
12. Whether ACC 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 ACC 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 ACC'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.
This request is being transferred in full to the Ministry for Ethnic Communities for response because
ACC understands the information is more closely connected with their functions. This decision was
made under section 14 of the Act.
If you have any questions about this transfer, you can email me a
t [email address].
Ngā mihi
Nicky Judd
Manager Official Information Act Services Government Engagement