New Zealand

Licensing, Authorisation & Market Access

New Zealand has no dedicated payment-services licensing statute; payment service providers currently operate under general financial-markets law. The Ministry of Business, Innovation and Employment published a discussion document on payment services regulation exploring a consolidated licensing and conduct regime, with scope extending to token-based payment models. Submissions on the discussion document closed on 3 July 2026, and MBIE has not proposed a preferred policy option at this stage; the document remains exploratory rather than a draft legislative instrument. The outcome of this process will determine whether New Zealand introduces an FCA-style or EU-style dedicated licensing regime for payment services, a structural change from the current reliance on the Financial Markets Conduct Act and related general financial law. For non-bank providers and token-based models, the discussion document's inclusion of these categories within scope signals that any resulting regime would reach beyond traditional bank-intermediated payment rails.

Outlook

The next material step is whichever direction MBIE takes following the closed consultation: a preferred-option paper, a further consultation round, or a move to draft legislation. Each of these would materially change the compliance perimeter for payment service providers, including token-based models, that currently sit outside a dedicated licensing framework.

Licensing, Authorisation & Market Access

New Zealand's consumer-credit conduct regulation moved to a new regulator this cycle. The Credit Contracts and Consumer Finance Amendment Act 2026 transferred CCCFA regulatory responsibility from the Commerce Commission to the Financial Markets Authority, effective 1 July 2026. Under the prior regime, consumer-credit lenders held certification issued by the Commerce Commission; under the new regime, that certification is replaced by FMA market-services licensing issued under the Financial Markets Conduct Act. This is a bank-and-nonbank-relevant change, since consumer-credit lending spans both bank and non-bank providers, and both now sit under FMA market-services licensing rather than Commerce Commission certification.

The Bill's third reading confirmed the 1 July 2026 transfer date, and the FMA has publicly framed the change as a move toward a more connected and coordinated approach to regulating financial market conduct, consistent with folding consumer-credit lending into the same regulatory house that already licenses a broad range of other financial-product and financial-service providers under the FMC Act. For non-bank consumer-credit lenders in particular, this means engaging with a different regulator, under a different licensing instrument, than the certification process they operated under previously.

Separately and on a related timeline, MBIE's payment-services regulation consultation, exploring a possible consolidated payments-licensing regime for non-bank payment service providers, closed 3 July 2026. Absent a bespoke payment-institution or e-money-institution passport akin to those seen in other jurisdictions, non-bank PSPs in New Zealand currently structure customer-fund protection through trust-account arrangements rather than a dedicated prudential licence. Whether this consultation produces a formal non-bank PSP licensing regime is a separate but related question to the CCCFA transfer, since both developments point toward a more codified, FMA-centred conduct and licensing perimeter for non-bank financial-service providers generally.

Outlook

The MBIE consultation outcome, expected around the first quarter of 2027, is the next material milestone for New Zealand's non-bank payments licensing landscape, and will indicate whether the FMA-centred consolidation visible in the CCCFA transfer extends to a dedicated payments-licensing regime for non-bank PSPs or leaves the trust-account-based structuring model in place.

Licensing, Authorisation & Market Access

New Zealand's consumer-credit conduct-regulation perimeter changed materially this cycle. The Credit Contracts and Consumer Finance Amendment Act 2026, following its third reading on 30 May 2026, transferred conduct regulation of consumer credit from the Commerce Commission to the Financial Markets Authority, effective 1 July 2026. This is not a narrow rebranding: the FMA now applies its market-services licensing model, previously used for financial advice, managed investment schemes and other regulated financial services, to consumer credit provision as well. From 1 July 2026, any entity acting as a creditor under a consumer credit contract requires an FMA consumer credit provider licence -- a new, explicit licensing perimeter where certification under the prior regime had applied.

The transition mechanics matter for market-access analysis as much as the substantive change itself. Existing certified lenders, along with entities already exempt via other FMA or RBNZ licensing, were automatically transitioned to an FMA market-services licence as at 1 July 2026, without a fresh application and without a transition fee. This is a bank-PSP versus non-bank-PI/EMI-relevant distinction: banks and other RBNZ-supervised entities already holding a relevant licence pass through the transition with minimal friction, while non-bank consumer-credit providers -- a category that includes many fintech and buy-now-pay-later-adjacent lenders -- face the same new FMA licensing perimeter but without the benefit of an existing RBNZ prudential relationship to lean on.

The practical market-access consequence is a consolidation of conduct oversight into a single, better-resourced regulator with an established licensing and supervisory model, at the cost of a new compliance step for any non-bank creditor that did not previously hold FMA-equivalent authorisation. This sits within a broader New Zealand pattern this cycle of regulatory consolidation into fewer, more capable supervisors across financial services generally.

Outlook

Watch for how the FMA calibrates its market-services licensing conditions specifically for consumer-credit providers, since the licence category is newly extended rather than purpose-built for this sector. The absence of a transition fee for existing certified lenders suggests a deliberately low-friction changeover; whether the FMA's ongoing supervisory approach to consumer credit proves similarly light-touch, or diverges materially from its historical approach to other market-services licensees, will only become clear once post-transition supervisory activity begins.

Licensing, Authorisation & Market Access

New Zealand's retail-payments market-access framework continues to operate under the Retail Payment System Act 2022, with two standing facts anchoring this cycle's assessment. First, Visa and Mastercard are categorised as designated networks under the Act, the classification that establishes the Commerce Commission's regulatory perimeter over these schemes. Second, the Commission's final interchange-fee decision - reducing merchant fees for Mastercard and Visa acceptance, alongside an associated network standard - took effect on 17 July 2025 and remains the operative merchant-fee baseline this cycle. Together these two facts describe a market-access environment in which the two major card networks operate under active competition-regulator oversight rather than an unregulated commercial arrangement. No new licensing or designation development beyond the standing interchange-fee and designated-network facts was evidenced this cycle; the framework is stable but the designation itself remains an active oversight tool.

Outlook

The interchange-fee decision and designated-network classification are the standing regulatory baseline against which any future Commerce Commission review would be measured; no forthcoming review or amendment was evidenced this cycle. The main development to watch is whether RBNZ's parallel payments-modernisation consultation intersects with the Commerce Commission's designated-network oversight as instant-payments infrastructure develops.

Licensing, Authorisation & Market Access

New Zealand's deposit-taking licensing framework is entering its final consultation phase before full commencement. The Reserve Bank of New Zealand opened the third and final tranche of Deposit Takers Act 2023 standards exposure drafts, paired with a crisis-preparedness policy package, with submissions due 11 September 2026. This tranche completes the standards architecture that will govern all licensed deposit takers once the Act reaches full effect on 1 December 2028, excluding the crisis-preparedness standards themselves. Alongside the standards consultation, RBNZ resolved a long-contested market-access question: from 1 December 2028, any deposit taker licensed under the DTA, bank or non-bank, may use the terms 'bank' and 'banking' in its branding. This removes a historic asymmetry under which brand access to the word 'bank' was effectively reserved for RBNZ-registered banks, and materially changes the competitive positioning available to non-bank deposit takers seeking to compete for retail deposits and payment relationships. Together, these two developments mark the most consequential re-founding of New Zealand's deposit-taking licensing perimeter since the 1989 Reserve Bank Act, moving the jurisdiction toward a single licensed-deposit-taker model that treats bank and non-bank entities under one authorisation and one standards framework.

Outlook

The 11 September 2026 consultation close is the immediate gating event: submissions will shape the final form of the tranche-3 standards and the crisis-preparedness package before RBNZ finalises them. Because the bulk of DTA standards take full effect only from 1 December 2028, market participants have a multi-year window to adapt licensing and branding arrangements, but the direction of travel toward a unified bank/non-bank licensing model is now settled policy rather than open question.

Operational Resilience & Critical Infrastructure

New Zealand's operational-resilience settings for deposit takers are being defined through the same consultation package driving the DTA's final standards tranche. The crisis-preparedness policy package accompanying the tranche-3 standards consultation includes operational-resilience and outsourcing standards, with submissions due 11 September 2026. This positions operational resilience as a core pillar of the DTA's licensing architecture rather than a standalone regime, meaning resilience obligations will apply uniformly across the unified bank/non-bank licensed-deposit-taker population once finalised.

Outlook

The finalisation timeline for these standards tracks the broader DTA schedule: crisis-preparedness standards are not expected to be issued until 2028, with effect from 2029, meaning New Zealand's operational-resilience regime for deposit takers will not be fully settled or in force for several years, leaving the September 2026 consultation as the key near-term opportunity to shape final settings.

Scheme & Network Compliance

New Zealand's card-scheme cost environment shifted materially with the introduction of the Mastercard and Visa Interchange Fee Network Standard 2025, which revoked and replaced the initial interchange-fee pricing standard set under the Retail Payment System Act 2022. The new standard took effect 1 December 2025 and is expected to save New Zealand businesses an additional NZD90 million annually, on top of savings already delivered by the Act's original interchange-fee intervention. This is a scheme-rule change operating within a statutory framework rather than a purely commercial scheme decision: the Retail Payment System Act 2022 gives the Commerce Commission standing authority to regulate interchange pricing standards for designated networks, and the 2025 Standard represents the second iteration of that regulatory intervention rather than a one-off adjustment.

The practical effect for merchants and acquirers is a further reduction in the cost of accepting Mastercard and Visa card payments in New Zealand, layered on top of the initial round of interchange-fee regulation that followed the 2022 Act. For scheme compliance purposes, this confirms that New Zealand's interchange regulation is an iterative, actively-managed regime rather than a fixed cap set once and left unchanged -- networks and the Commerce Commission continue to revisit and tighten pricing standards as the regulatory framework matures.

Outlook

The key indicator to watch is whether the Commerce Commission moves toward a third iteration of interchange-fee regulation, or whether the 2025 Standard represents a settling point for card-scheme pricing under the Retail Payment System Act framework for the near term. Given the pattern of two successive standards in under four years, scheme compliance teams operating in New Zealand should not assume the current pricing standard is durable over a multi-year horizon.

Payment Corridor Dynamics

New Zealand's open-banking infrastructure moved from regulatory framework into mandatory operational reality this cycle. Banking regulations under the Customer and Product Data Act 2025 came into force on 1 December 2025, requiring the country's big-four banks -- ANZ, ASB, BNZ and Westpac New Zealand -- to make standardised open-banking APIs available from that date. Kiwibank is joining the mandatory API regime in stages through 2026 rather than at the same commencement date as the big four, reflecting a differentiated rollout timeline for a smaller domestic bank relative to the major incumbents.

The Commerce Commission's open letter of 5 March 2026 provides the clearest recent progress signal on implementation: it records industry progress on the API v2.3 technical specification and on the Ministry of Business, Innovation and Employment's accreditation regime for third parties seeking to consume bank-exposed data and payment-initiation APIs. This is a bank-PSP-centric development at this stage -- the mandatory API obligation sits on the banks themselves, with non-bank third parties positioned as consumers of that infrastructure once MBIE's accreditation regime is operational, rather than as parties directly obligated under the Act's banking regulations. The corridor-dynamics significance is that New Zealand's account-to-account payment infrastructure is now being built on a statutory, API-standardised foundation rather than on ad hoc bilateral bank arrangements, which is the necessary precondition for any future domestic account-to-account payment product to scale across the major banks simultaneously.

Outlook

The pace and completeness of Kiwibank's staged API rollout through the remainder of 2026, together with the rate at which MBIE actually accredits third parties able to consume the big-four APIs, will determine whether open banking in New Zealand becomes a genuinely competitive account-to-account corridor within the next few cycles or remains a compliance-driven infrastructure build with limited immediate third-party product activity.

Product Innovation & Market Development

The Ministry of Business, Innovation and Employment's payment-services regulation consultation, exploring a possible consolidated payments-licensing regime for non-bank payment service providers, closed 3 July 2026. This consultation sits at the centre of New Zealand's product-innovation and market-development trajectory for payments, since its outcome will determine whether non-bank PSPs continue to structure customer-fund protection through trust-account arrangements, the current standing model absent a bespoke payment-institution or e-money-institution licensing passport, or move to a formal, dedicated licensing regime.

This consultation is distinct from, but adjacent to, the FMA's absorption of CCCFA conduct regulation from 1 July 2026, discussed under Licensing, Authorisation & Market Access: the CCCFA transfer concerns consumer-credit lending conduct specifically, while the MBIE consultation concerns payment-services licensing more broadly, but both point toward the same broader theme of a more codified, FMA-adjacent conduct and licensing perimeter developing for non-bank financial-service providers in New Zealand.

Open banking's continued build-out under the Customer and Product Data Act 2025, discussed under Payment Corridor Dynamics, is the other product-innovation-adjacent thread this cycle, since the accreditation regime MBIE administers for the Consumer Data Right determines which third-party providers, including non-bank product innovators, can access customer banking data to build new payment and financial products.

Outlook

The MBIE payment-services consultation outcome, expected around the first quarter of 2027, is the key structural signal to watch for New Zealand's non-bank payments product landscape. A move toward a consolidated licensing regime would materially change the compliance profile for non-bank PSPs and could accelerate product innovation by providing regulatory certainty currently absent under the trust-account-based structuring model.

Product Innovation & Market Development

Open banking's development pace in New Zealand drew explicit criticism this cycle. Consumer NZ and other commentators criticised banks for not moving quickly enough to enable open banking that would let third-party applications use banking data for bank-to-bank transfers, and RBNZ's own payments-modernisation review explicitly flagged a lack of system-wide leadership on open banking as a contributing factor. This links New Zealand's open-banking product-innovation gap directly to the same underlying infrastructure and leadership weaknesses motivating RBNZ's broader payments-modernisation consultation, rather than treating open banking as an isolated product-development question. The criticism is assessed rather than confirmed in its specific attribution of blame, but the underlying fact that RBNZ's own review flags a leadership gap is a notable admission from the regulator itself about the pace of product innovation in the New Zealand market.

Outlook

Whether RBNZ's payments-modernisation consultation produces a concrete mechanism for system-wide open-banking leadership - rather than leaving development to individual banks' own pace - is the key question this domain will be tested against as the consultation progresses toward its 27 October 2026 submissions deadline.

Product Innovation & Market Development

New Zealand's open-banking rollout reached a landmark milestone this cycle. The Customer and Product Data (Banking and Other Deposit Taking) Standards 2025 came into force on 1 December 2025, designating the big four banks as data holders for both account-information and payment-initiation actions, with no fees permitted for data transfers. Kiwibank is joining on a phased timetable, with payments designation from 1 June 2026 and account-information designation from 1 December 2026, closing the coverage gap left by the big-four-only launch. The Commerce Commission is actively tracking delivery: its 5 March 2026 open letter monitors bank progress on API v2.3 and signals regulatory interest in enabling third-party competition to existing payment networks through the open-banking rails. Together, these developments make 2025-2026 the effective launch window for New Zealand's Consumer Data Right in banking, moving the jurisdiction from a voluntary, industry-led API standards effort to a designated, regulator-monitored open-banking regime.

Outlook

Kiwibank's account-information designation on 1 December 2026 is the next concrete milestone that will complete big-bank CDR coverage. The Commerce Commission's ongoing delivery tracking, and its stated interest in third-party competition to existing payment networks, signal that open banking is being positioned as a lever for broader payments-market contestability, not solely a data-portability measure.

Consumer Protection & APP Fraud

Authorised push-payment fraud protection for New Zealand bank customers has moved from voluntary practice to a defined liability and compensation framework this cycle. Effective 30 November 2025, the Code of Banking Practice's anti-scam amendments introduced Confirmation of Payee and a reimbursement commitment covering combined losses up to NZD500,000 for authorised push-payment scams, funded by the banking sector rather than borne solely by defrauded customers. This represents a material transfer of scam-loss risk from consumers to banks, contingent on the specific commitments made under the Code. The compensation framework operates alongside mule-account information-sharing between banks, which supports both fraud detection and broader financial-crime monitoring objectives.

Outlook

The practical operation of the reimbursement cap and the claims process arising from it will be the key indicator of whether this framework meaningfully shifts consumer outcomes, as will any read-across from the Fair Trading Act Amendment Bill's platform-disruption defence once it is enacted.