title: New Zealand Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/new-zealand/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # New Zealand NZ schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 58 sourced findings · 123 sources in the cumulative register 14 Modules baseline.modules[] 58 Findings modules[].findings[] 35 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal New Zealand's open-banking regime passed through a structural governance transition this cycle. The Payments NZ API Centre, which had run the industry-led phase of open banking since 2019, ceased operating on 30 September 2026. The Ministry of Business, Innovation and Employment has assumed full statutory stewardship of the standards that the API Centre previously managed, entering a licensing agreement with Payments NZ that incorporates the API Centre's v2.3.3 API standards and Customer Standard v1.1 by reference into the Customer and Product Data (Banking and Other Deposit Taking) Standards 2025. This moves New Zealand's open-banking governance model from industry self-regulation to direct ministry oversight under statute, a change in the regulatory architecture rather than in the underlying technical standards themselves, which carry over unchanged into the new regime. The transition occurred against a backdrop of continued volume growth in the open-banking ecosystem: 545,681 open-banking payments were completed in August 2026, up 36 percent month-on-month, worth NZ$152.9 million. That growth trajectory held through the last full month before the API Centre's closure, indicating the governance hand-over did not coincide with any disruption to usage. #### Other Developments **A cross-regulator consultation on the next phase of payments settings** -- covering faster payments, stronger safeguards, competition and innovation, and run jointly by the Financial Markets Authority, MBIE and the Reserve Bank of New Zealand -- closes 27 October 2026. The consultation's scope suggests the regulatory agenda beyond open banking is also under active review, though its specific proposals were not detailed in reporting reaching this cycle. #### Cross-Monitor Connections The shift of open-banking standards stewardship to MBIE under the Customer and Product Data Act 2025 intersects with data-protection-adjacent obligations around indirect data collection and consent that data-protection monitoring tracks separately for New Zealand; the statutory basis for data-sharing standards under an account-to-account payment architecture is relevant to both monitors' coverage of the same underlying infrastructure. #### Outlook The near-term date to watch is 27 October 2026, when the cross-regulator consultation on faster payments, stronger safeguards, competition and innovation closes. Its outcome will indicate whether MBIE's new statutory stewardship role extends further into active rule-making beyond the open-banking standards it has just inherited, or whether the current licensing-agreement approach -- incorporating existing API Centre standards by reference -- represents a stable governance endpoint for now. Continued volume growth through the governance transition suggests market participants have adapted operationally to the hand-over without disruption to date. _6 earlier updates not shown here._ ###### Standing brief · as of 29 June 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal New Zealand's payments regime is best understood by what it lacks. The country has no dedicated e-money or payment-institution licence; payment service providers register on the Financial Service Providers Register under the Financial Service Providers Act 2008 and pick up Financial Markets Conduct Act and CoFI obligations depending on whether they issue debt securities or take deposits. Customer funds are protected not by statutory segregation but by trust: PSPs and e-money providers hold customer money on trust in a licensed-bank trust account to avoid debt-security characterisation under the FMC Act. There is no stablecoin-specific statute and no mandatory authorised-push-payment reimbursement regime. Taken together, this is an architecture defined by its divergence from EU and UK frameworks — and it is now under active review. That review is the forward signal that matters most. The Ministry of Business, Innovation & Employment opened a payment-services regulation consultation in May 2026, with submissions closing 3 July 2026, asking whether New Zealand's multi-statute payments rules remain fit for purpose and exploring a possible consolidated payments-licensing regime. We carry this as a discussion document rather than a proposed regime; the consultation is the single most consequential forward question for market access by non-bank PSPs. A consolidated licensing route would materially reshape how non-bank operators enter the New Zealand market, where today the absence of a bespoke PI/EMI passport route pushes structuring toward the trust-account model. #### Other Developments The Retail Payment System Act 2022 interchange regime is New Zealand's most active regulatory front. Under the Act, the Commerce Commission designated the Visa and Mastercard credit and debit networks and set interchange caps; the Mastercard and Visa Interchange Fee Network Standard 2025 revoked and replaced the initial pricing standard on 1 December 2025, cutting in-person domestic credit interchange from roughly 0.8% to 0.3%. Caps on foreign-issued Visa and Mastercard cards then came into force on 1 May 2026 — the first time overseas-card interchange has been regulated in New Zealand. The Commission's July 2025 Final Decision added an anti-avoidance 'mathematical ceiling' on issuer compensation to prevent schemes offsetting interchange reductions with other fees, while commercial credit-card interchange was left uncapped and is under active investigation. The direction of travel is sustained downward pressure rather than a settled endpoint. Two structural access-widening reforms are now live. The Customer and Product Data Act 2025 creates a legal right for customers to access and share data and to authorise payments; banking-sector designation — regulated open banking — took effect on 1 December 2025, incorporating Payments NZ API Centre standards by reference, with five API providers (ANZ, ASB, BNZ, Westpac, Kiwibank) on standardised-API timelines and nine third parties live at go-live. Separately, in March 2025 the Reserve Bank of New Zealand completed a review of Exchange Settlement Account System access and revised its criteria to expand eligibility to non-bank entities in two phases — first licensed non-bank deposit takers, then PSPs, overseas deposit takers and designated FMI operators. Together these reduce non-bank dependence on bank sponsorship and seed account-to-account competition against card rails; an early demonstration is Payap, a BNZ-backed QR-based A2A app powered by Centrapay that reached number one among free finance apps in New Zealand's iOS App Store. Not every reform is advancing. The Retail Payment System (Ban on Merchant Surcharges) Amendment Bill, which proposes to ban surcharges on in-store EFTPOS, Visa and Mastercard debit and credit payments, passed first reading in September 2025 and was referred to the Finance and Expenditure Committee. As of June 2026 the Bill has stalled while the Government considers wider implications, and surcharging remains legal under current rules. We carry this status correction explicitly: the forward outcome is uncertain. #### Cross-Monitor Connections New Zealand's AML/CFT framework rests on the AML/CFT Act 2009 and is consolidating under the Department of Internal Affairs as a single supervisor with a new levy funding model, with a customer risk-rating requirement and online-marketplace coverage effective from 1 June 2025. This intelligence is sourced from the Sentinel feed and carried as provenance, not original WPM analysis. The bank-versus-non-bank supervision-gap reform is the material payments development; any original illicit-finance, sanctions or de-risking analysis on New Zealand or its Pacific corridors belongs to FIM, not the World Payments Monitor. The same boundary applies to the Pacific remittance picture: RBNZ presses banks to keep corridors open and warns that AML laws are not an excuse to de-bank the Pacific, but the underlying illicit-finance use of those corridors is a FIM cross-reference. #### Outlook The near-term calendar is dense. MBIE's payments-licensing consultation closes 3 July 2026, and its outcome will determine whether New Zealand moves toward a consolidated regime or retains its multi-statute status quo. From 1 July 2026 consumer lenders must be licensed by the FMA, replacing the prior Commerce Commission certification requirement and consolidating conduct supervision over non-bank lenders. The Cuscal acquisition of Worldline's New Zealand activities (Paymark) was expected to complete by 30 June 2026 but had not completed at the run date, pending a French Works Council consultation and a Worldline put option. The surcharge-ban Bill remains the principal source of forward uncertainty. The operating environment is tightening across licensing, interchange, open banking, settlement access and AML supervision simultaneously — a moderate-risk jurisdiction in active, multi-front reform. trust tier: ai_unverified ###### Latest update · 4 October 2026 #### Regulatory Status New Zealand's payments regulatory architecture remains built on general financial-markets law rather than a dedicated payment-services statute. The Ministry of Business, Innovation and Employment's discussion document on payment services regulation, with submissions closed 3 July 2026, is the live policy vehicle testing whether a consolidated licensing and conduct regime, covering token-based models, should be introduced. Separately, governance of open-banking technical standards is reported to be moving from the Payments NZ API Centre, which is understood to be closing at the end of September 2026, to MBIE, which is reported to be purchasing rights to the Version 3.0 API Centre specifications. #### Outlook The direction MBIE takes after its payment-services consultation, and the completion of the open-banking governance handover from Payments NZ, are the two developments that will define New Zealand's payments regulatory trajectory in the near term. _1 earlier update not shown here._ ###### Standing brief · as of 29 June 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status New Zealand is a moderate-risk, actively reforming payments jurisdiction whose regime is best characterised by its divergence from EU and UK frameworks. There is no dedicated e-money or payment-institution licence: PSPs register on the Financial Service Providers Register under the Financial Service Providers Act 2008 and pick up Financial Markets Conduct Act and CoFI obligations depending on whether they issue debt securities or take deposits. Customer-fund protection runs through trust rather than statutory segregation — PSPs and e-money providers hold customer funds on trust in a licensed-bank trust account to avoid debt-security characterisation under the FMC Act. The Ministry of Business, Innovation & Employment opened a payment-services regulation consultation in May 2026, closing 3 July 2026, exploring a possible consolidated payments-licensing regime; this is carried as a discussion document, not a proposed regime. The most active regulatory front is interchange. Under the Retail Payment System Act 2022, the Commerce Commission designated the Visa and Mastercard networks and set caps; the Interchange Fee Network Standard 2025 replaced the initial pricing standard on 1 December 2025, cutting in-person domestic credit interchange from roughly 0.8% to 0.3%, and foreign-issued card caps came into force on 1 May 2026 — a first for New Zealand. The Commission's July 2025 Final Decision added an anti-avoidance ceiling, with commercial credit-card interchange left uncapped and under investigation. Two structural access-widening reforms are live: regulated open banking under the Customer and Product Data Act 2025 (effective 1 December 2025) and the RBNZ March 2025 expansion of ESAS settlement-account access to non-bank entities in two phases. On infrastructure, ESAS is a designated settlement system under the Financial Market Infrastructures Act 2021 with statutory settlement finality, and the industry is migrating to ISO 20022 under a coexistence strategy, with hardware upgraded in September 2024. On consumer protection, there is no statutory mandatory APP-fraud reimbursement regime; the New Zealand Bankers' Association's voluntary scam scheme has been in force since December 2025 but is criticised as weaker than the UK's mandatory regime. There is no stablecoin-specific statute; RBNZ's June 2023 'increased vigilance, not regulation' posture remains unchanged. AML/CFT supervision is consolidating under the Department of Internal Affairs as a single supervisor with a new levy model (this intelligence is Sentinel-fed; illicit-finance analysis is routed to FIM). On commercial activity, the Shift4/Smartpay acquisition is completed, the Cuscal/Paymark (Worldline NZ) acquisition is pending completion conditions at the run date, and Klarna/Laybuy consolidated the BNPL segment. #### Outlook The operating environment is tightening across licensing, interchange, open banking, settlement access and AML supervision simultaneously, and the regulatory direction is tightening overall. The near-term calendar is dense: MBIE's payments-licensing consultation closes 3 July 2026; from 1 July 2026 consumer lenders must be FMA-licensed; the Cuscal/Paymark completion is expected around 30 June 2026 but had not completed at the run date. The principal source of forward uncertainty is the stalled Retail Payment System (Ban on Merchant Surcharges) Amendment Bill — surcharging remains legal, and the Bill's outcome and timing are unresolved. New Zealand is a jurisdiction in active, multi-front reform, with structural access-widening (open banking and ESAS access) running alongside continued correspondent-banking de-risking pressure on Pacific corridors. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-06-27 Open banking / Consumer Data Right (CDR) governance has moved from industry self-regulation to direct MBIE statutory stewardship: the Payments NZ API Centre ceased operating on 30 September 2026, and MBIE now leads open-banking standards management under the Customer and Product Data Act 2025. Movement — CHANGED MBIE assumed full statutory stewardship of open-banking standards following the API Centre's 30 September 2026 closure_Structural regulatory hand-over of open-banking governance confirmed by a Tier-1 MBIE source this cycle_ Horizon · 2026-07 (±year) MBIE payment-services regulation consultation — possible consolidated payments-licensing regime_consultation · T3_ Standing sub-brief · as of 29 June 2026 274 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access New Zealand operates no dedicated e-money or payment-institution licence. Payment service providers register on the Financial Service Providers Register under the Financial Service Providers Act 2008 and acquire Financial Markets Conduct Act and CoFI obligations depending on whether they issue debt securities or take deposits. The Financial Markets Authority administers financial-institution licensing where applicable, but there is no bespoke PI/EMI passport route comparable to EU or UK frameworks. For any non-bank payments operator entering New Zealand, this absence shapes structuring decisions — typically toward the trust-account model — and is the central reason the consolidation question is now on the policy table. This applies to both bank PSPs and non-bank operators, though it is the non-bank market-entry route that is most directly governed by the registration-plus-obligations design. The live forward item is the Ministry of Business, Innovation & Employment payment-services regulation consultation, launched in May 2026 with submissions closing 3 July 2026. The discussion document asks whether New Zealand's multi-statute payments rules remain fit for purpose and explores a possible consolidated payments-licensing regime. We carry this as a discussion document, not a proposed regime; confidence is held at Assessed pending a registered primary MBIE anchor. A consolidated licensing route would materially reshape market access for non-bank PSPs and is the single most consequential forward regulatory question in this module. #### Outlook The consultation close on 3 July 2026 is the immediate inflection point. Whether MBIE moves toward a consolidated regime or retains the existing multi-statute architecture will determine the entry pathway for non-bank payments operators for years. Until then, the trust-account structuring model and FSPR-plus-obligations approach remain the operative reality. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access New Zealand's open-banking market access framework underwent a structural governance shift this cycle. The Payments NZ API Centre, which had administered the industry-led phase of open banking since 2019, ceased operating on 30 September 2026. In its place, the Ministry of Business, Innovation and Employment has assumed full statutory stewardship of open-banking standards management. MBIE entered a licensing agreement with Payments NZ that incorporates the API Centre's v2.3.3 API standards and Customer Standard v1.1 by reference into the Customer and Product Data (Banking and Other Deposit Taking) Standards 2025. This represents a move from industry self-regulation toward direct ministry oversight exercised under statute, though the underlying technical API standards themselves carry over unchanged from the prior regime into the new one. A further regulatory development sits alongside this transition: a cross-regulator consultation covering faster payments, stronger safeguards, competition and innovation -- run jointly by the Financial Markets Authority, MBIE and the Reserve Bank of New Zealand -- closes 27 October 2026. This consultation's scope indicates that New Zealand's payments regulatory agenda is under active review beyond the open-banking hand-over alone, though the specific proposals under consideration were not detailed in the reporting reaching this cycle. #### Outlook The consultation closing 27 October 2026 is the near-term signal to watch for whether MBIE's new stewardship role extends into further active rule-making on faster payments, safeguards or competition settings, beyond the open-banking standards it has just inherited by licensing agreement. **5 earlier distinct update(s)** Periodic update · new data 2026-10-04 #### 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. Periodic update · new data 2026-09-28 #### 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. Periodic update · new data 2026-09-21 #### 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. Periodic update · new data 2026-09-14 #### 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. Periodic update · new data 2026-08-11 #### 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. **Sources and findings (4)** 1. T1 [https://www.fma.govt.nz/business/services/financial-institutions/financial-institution-licensing/](https://www.fma.govt.nz/business/services/financial-institutions/financial-institution-licensing/) retrieved 2026-06-27 2. T3 [https://multilaw.com/Multilaw/ZENTSO/BusinessGuides/Presentation/Section_Home.aspx?GuideId=2&GuideCountry=New+Zealand&GuideSection=382](https://multilaw.com/Multilaw/ZENTSO/BusinessGuides/Presentation/Section_Home.aspx?GuideId=2&GuideCountry=New+Zealand&GuideSection=382) retrieved 2026-06-27 3. T3 [https://www.finextra.com/pressarticle/104320/nz-regulator-clarifies-licensing-requirements-for-e-money-and-payment-service-providers](https://www.finextra.com/pressarticle/104320/nz-regulator-clarifies-licensing-requirements-for-e-money-and-payment-service-providers) retrieved 2026-06-27 4. T3 [https://blockchain.org.nz/2026/06/03/big-month-for-digital-assets-in-nz-momentum-media-and-may-policy-meetings/](https://blockchain.org.nz/2026/06/03/big-month-for-digital-assets-in-nz-momentum-media-and-may-policy-meetings/) retrieved 2026-06-27 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-06-27 Conduct is governed by the FMC Act 2013 and the CoFI regime (Financial Markets (Conduct of Institutions) Amendment Act 2022), with FMA as conduct regulator requiring fair conduct programmes. There is no EMI-style statutory safeguarding/segregation regime; PSPs typically hold customer funds on trust in a licensed-bank trust account. All retail financial service providers must belong to one of four approved dispute-resolution schemes. Consumer-lending licensing by the FMA begins 1 July 2026. Horizon · 2026-07 (±quarter) FMA assumes consumer-lender licensing (CCCFA transfer from Commerce Commission)_in_force_pending · T1_ Standing sub-brief · as of 29 June 2026 248 words · last cycle 2026-08-06 #### Conduct, Safeguarding & Promotions Conduct in New Zealand is governed by the Financial Markets Conduct Act 2013 and the CoFI regime, which requires fair-conduct programmes for banks, insurers and licensed non-bank deposit takers. There is no EMI-style statutory safeguarding or segregation regime. Instead, PSPs and e-money providers typically hold customer funds on trust in a licensed-bank trust account, a structure adopted to avoid debt-security characterisation under the FMC Act. This trust-based safeguarding is the defining feature of New Zealand non-bank fund protection — and it is materially weaker and more bespoke than EU or UK statutory segregation, making it a key diligence point for any operator handling New Zealand customer funds. The distinction between bank PSPs (covered by prudential and conduct regimes) and non-bank PI/EMI operators (relying on contractual trust arrangements) is sharp in this module. A dated conduct change is imminent. From 1 July 2026, consumer lenders must be licensed by the FMA, replacing the prior Commerce Commission certification requirement; certified lenders are auto-deemed licensed, while mobile traders remain registration-only. The CCCFA Amendment Bill passed its third reading on 30 May 2026, with the transfer effective 1 July 2026. This consolidates the conduct regulator's remit over non-bank lenders. #### Outlook The 1 July 2026 transfer of consumer-lender supervision to the FMA is a near-certain event requiring monitoring of post-transfer operational implementation. The trust-account safeguarding model remains the standing position absent any statutory segregation reform, and any MBIE consolidation outcome could eventually intersect with how customer funds are protected. Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions New Zealand's bank conduct framework absorbed a significant anti-scam upgrade this cycle. Effective 30 November 2025, New Zealand Bankers' Association member banks brought five anti-scam commitments into force under the Code of Banking Practice, including Confirmation of Payee functionality and a reimbursement commitment covering authorised push-payment scam losses up to a combined NZD500,000, together with mule-account information sharing between banks. This is a material shift of fraud-loss risk from consumers toward the banking sector, paired with a data-sharing channel between banks that carries financial-crime relevance beyond pure consumer protection. The government has moved to extend platform-level accountability: a Fair Trading Act Amendment Bill, introduced in May 2026, creates a statutory defence for online platforms that take action to disrupt scam content, following a November 2025 announcement of government intent to legislate in this area. Together, these developments position New Zealand's conduct regime as actively responding to authorised push-payment fraud through both a private industry-code commitment and a legislative platform-accountability mechanism, rather than relying on either instrument alone. #### Outlook Passage of the Fair Trading Act Amendment Bill will be the key marker to watch, since it converts a bank-sector industry commitment into a broader, platform-inclusive statutory framework. The interaction between the Code of Banking Practice's mule-account information-sharing provisions and any future AML/CFT-specific guidance is a live area for further regulatory convergence. **Sources and findings (4)** 1. T3 [https://chambers.com/content/item/4201](https://chambers.com/content/item/4201) retrieved 2026-06-27 2. T1 [https://www.fma.govt.nz/consumer/everyday-finance/disputes-and-consumer-protection/](https://www.fma.govt.nz/consumer/everyday-finance/disputes-and-consumer-protection/) retrieved 2026-06-27 3. T3 [https://www.minterellison.co.nz/insights/new-zealand-crypto-asset-regulation](https://www.minterellison.co.nz/insights/new-zealand-crypto-asset-regulation) retrieved 2026-06-27 4. T1 [https://fsp-register.companiesoffice.govt.nz/](https://fsp-register.companiesoffice.govt.nz/) retrieved 2026-06-27 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-06-27 NZ has NO stablecoin-specific legislation. Stablecoins are assessed case-by-case under the FMC Act (potential debt-security characterisation). RBNZ adopted a 'increased vigilance, not regulation' posture from June 2023 following the Future of Money consultation, and is researching a digital NZD (CBDC) with no launch timeline. A domestic NZD-pegged stablecoin (NZDD) launched November 2023. Where a stablecoin operates as a payment system, the Commerce Commission may designate it under the Retail Payment System Act 2022. Standing sub-brief · as of 29 June 2026 265 words · last cycle 2026-08-06 #### Stablecoins & Digital Money New Zealand has no stablecoin-specific legislation. The Reserve Bank of New Zealand adopted an 'increased vigilance, not regulation' posture in June 2023 following the Future of Money consultation, working through the Council of Financial Regulators; stablecoins are assessed case-by-case under the Financial Markets Conduct Act debt-security characterisation. This posture dates to June 2023 and we carry it with a vintage caveat — no subsequent RBNZ announcement as of June 2026 has altered it and no stablecoin-specific regulation has been introduced. There is no source confirming whether the vigilance framework has been operationally implemented or revised in the intervening three years. A latent backstop exists. Where a stablecoin operates as a payment system, the Retail Payment System Act 2022 empowers the Commerce Commission to designate and regulate it as a retail payment network, though this is unlikely to be used until a network reaches systemic importance; the power has not yet been exercised against any stablecoin network. On the market side, NZDD — the first NZD-pegged stablecoin — launched in November 2023 by Easy Crypto, reportedly backed 1:1 with funds held in a local bank account per audit reports. That reserve-backing claim rests on a single source and no primary attestation has been verified. #### Outlook The stablecoin posture is stable but stale, resting on a three-year-old vigilance statement. Issuers must continue to structure around FMC Act debt-security tests, and the contrast with MiCA and UK regimes remains material for cross-border issuers. The Commerce Commission's designation power is a backstop that would only engage if a stablecoin payment network scaled to systemic significance. Periodic update · new data 2026-08-11 #### Stablecoins & Digital Money The Financial Markets Authority issued New Zealand's first stablecoin product determination this cycle, declaring the NZDD stablecoin, issued by Easy Crypto/ECDD Holdings, not a financial product under the Financial Markets Conduct Act 2013, effective 11 March 2026. The determination is conditioned on the product remaining non-yield-bearing and subject to reserve, disclosure and verification conditions; the FMA has explicitly flagged that yield-bearing features would revert the product to regulated-product status. This creates a live regulatory boundary test for stablecoin issuers operating in New Zealand: structure a token as a non-yielding, reserve-backed payment instrument and it sits outside financial-product regulation, but any yield feature pulls it back inside the perimeter. The determination emerged alongside the FMA's broader fintech sandbox expansion, reflecting a calibrated, product-by-product approach to digital-money regulation rather than a blanket framework. #### Outlook Further product determinations testing the non-yielding boundary are the key signal to watch, as is any indication that NZDD's design evolves toward yield-bearing features, which would trigger a reclassification. **Sources and findings (5)** 1. T1 [https://www.rbnz.govt.nz/hub/news/2023/06/rbnz-ramps-up-monitoring-of-stablecoins-and-cryptoassets](https://www.rbnz.govt.nz/hub/news/2023/06/rbnz-ramps-up-monitoring-of-stablecoins-and-cryptoassets) retrieved 2026-06-27 2. T3 [https://www.minterellison.co.nz/insights/new-zealand-crypto-asset-regulation](https://www.minterellison.co.nz/insights/new-zealand-crypto-asset-regulation) retrieved 2026-06-27 3. T3 [https://www.minterellison.co.nz/insights/new-zealand-crypto-asset-regulation](https://www.minterellison.co.nz/insights/new-zealand-crypto-asset-regulation) retrieved 2026-06-27 4. T3 [https://www.moneyhub.co.nz/stablecoins.html](https://www.moneyhub.co.nz/stablecoins.html) retrieved 2026-06-27 5. T3 [https://stripe.com/resources/more/digital-currency-in-new-zealand](https://stripe.com/resources/more/digital-currency-in-new-zealand) retrieved 2026-06-27 ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-06-27 RBNZ launched a payments-modernisation consultation (issues paper, ~18 Aug 2026) proposing to overhaul NZ's retail payments infrastructure — including instant-payments capability — citing an estimated NZ$700m-$1.3bn/year economic benefit; submissions close 27 October 2026. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/new-zealand/) Standing sub-brief · as of 29 June 2026 184 words · last cycle 2026-08-25 #### Operational Resilience & Critical Infrastructure The Exchange Settlement Account System, New Zealand's real-time gross settlement system, is a designated settlement system under the Financial Market Infrastructures Act 2021 and a systemically important FMI, supervised by the Reserve Bank of New Zealand's Prudential Supervision Department with statutory settlement finality and insolvency protection. These features underpin the legal certainty of all wholesale NZD settlement and are foundational for any participant. This is bank-PSP infrastructure at its core, anchoring the wholesale settlement layer. New Zealand's banking industry is migrating to ISO 20022. RBNZ adopted a coexistence strategy supporting both legacy FIN (MT) and new ISO 20022 (MX) formats in ESAS, with the underlying ESAS and NZClear database hardware upgraded in September 2024. The coexistence approach affects message-format readiness and data-richness for all ESAS participants and for correspondent flows. #### Outlook New Zealand has no DORA-equivalent consolidated operational-resilience regime; resilience runs through the FMI Act 2021 framework and the ISO 20022 migration. The coexistence strategy means format-readiness will remain a live operational consideration for participants as the industry completes the migration, but the settlement-finality and FMI-designation foundations are settled. Periodic update · new data 2026-09-14 #### Operational Resilience & Critical Infrastructure The Reserve Bank of New Zealand's payments-modernisation issues paper, launched around 18 August 2026, is this cycle's central operational-resilience development. The paper proposes to overhaul New Zealand's retail payments infrastructure, including instant-payments capability, and cites an estimated NZ$700 million to NZ$1.3 billion per year economic benefit from modernisation. RBNZ Assistant Governor Karen Silk framed the existing retail payments system as falling behind global standards, and the paper's own estimate that roughly NZ$2 trillion in retail payment flows moves between New Zealand banks annually underscores the scale against which any infrastructure weakness is measured. Submissions on the issues paper close 27 October 2026. This is an early-stage consultation rather than a committed build: RBNZ's own framing points toward a subsequent roadmap or business case and further consultation before any instant-payments capability is actually implemented. #### Outlook The 27 October 2026 submissions deadline is the next concrete milestone. What follows - a roadmap, business case, or further consultation round - will determine the pace at which any instant-payments capability actually reaches New Zealand's critical payments infrastructure, and whether the NZ$700 million to NZ$1.3 billion annual benefit estimate survives contact with implementation planning. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### 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. **Sources and findings (3)** 1. T1 [https://www.rbnz.govt.nz/payments-and-settlement-systems/exchange-settlements-account-system/esas-overview](https://www.rbnz.govt.nz/payments-and-settlement-systems/exchange-settlements-account-system/esas-overview) retrieved 2026-06-27 2. T1 [https://www.rbnz.govt.nz/payments-and-settlement-systems/exchange-settlements-account-system/esas-and-the-financial-system](https://www.rbnz.govt.nz/payments-and-settlement-systems/exchange-settlements-account-system/esas-and-the-financial-system) retrieved 2026-06-27 3. T1 [https://www.rbnz.govt.nz/payments-and-settlement-systems/exchange-settlements-account-system/esas-overview](https://www.rbnz.govt.nz/payments-and-settlement-systems/exchange-settlements-account-system/esas-overview) retrieved 2026-06-27 ### W4 Scheme & Network Compliance Confirmed confirmed 2026-06-27 RPSA 2022 designates Visa/Mastercard networks; Interchange Fee Network Standard 2025 replaced initial pricing standard 1 Dec 2025 (in-person credit ~0.8%->0.3%); foreign-issued card caps in force 1 May 2026. Standing sub-brief · as of 29 June 2026 195 words · last cycle 2026-10-04 #### Scheme & Network Compliance Under the Retail Payment System Act 2022, the Commerce Commission designated the Visa and Mastercard credit and debit networks and set interchange caps. The Mastercard and Visa Interchange Fee Network Standard 2025 revoked and replaced the initial pricing standard on 1 December 2025, with in-person domestic credit interchange cut from roughly 0.8% to 0.3%. This directly reshapes card-acceptance economics for every New Zealand merchant and the interchange revenue of issuers — a headline regulatory intervention affecting both bank and non-bank participants in the card value chain. The regime then extended further. Caps on foreign-issued Visa and Mastercard cards came into force on 1 May 2026 — the first time overseas-card interchange has been regulated in New Zealand. This affects acceptance costs for tourism and cross-border merchants and is a first-of-kind move in the New Zealand market. #### Outlook Scheme and network compliance is escalating. The domestic and foreign-card caps establish a tightening trajectory, and continued regulatory pressure on interchange beyond the headline caps is signalled by the anti-avoidance work tracked in the legal and litigation module. Merchants and issuers should expect the interchange regime to remain New Zealand's most active card-regulation front. Periodic update · new data 2026-10-04 #### Scheme & Network Compliance Governance of New Zealand's open-banking (consumer data right) technical standards is reported to be transferring from the industry-run Payments NZ API Centre to MBIE. The API Centre is understood to be closing at the end of September 2026, with MBIE purchasing rights to the Version 3.0 API Centre specifications so the technical standards can continue under the Ministry's stewardship. This is a structural shift in who sets and administers the scheme-level technical standards that banks and third-party providers build against for open banking in New Zealand, moving that function from an industry body to a government ministry. No primary MBIE confirmation of the API Centre's closure or the specification purchase has been independently located this cycle; the position currently rests on law-firm commentary rather than a Ministry announcement. #### Outlook Whether and how MBIE formally assumes standards governance, and whether the Version 3.0 specifications continue unchanged or are revised once under Ministry control, will determine the degree of continuity third-party providers and banks can expect in their existing open-banking integrations through the transition period around the API Centre's closure. **1 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### 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. **Sources and findings (4)** 1. T1 [https://www.comcom.govt.nz/regulated-industries/projects/retail-payment-system/](https://www.comcom.govt.nz/regulated-industries/projects/retail-payment-system/) retrieved 2026-06-27 2. T1 [https://www.legislation.govt.nz/act/public/2022/0021/latest/whole.html](https://www.legislation.govt.nz/act/public/2022/0021/latest/whole.html) retrieved 2026-06-27 3. T3 [https://blog.eftpos.co.nz/blog/interchange-fee-changes-what-they-mean-for-your-business](https://blog.eftpos.co.nz/blog/interchange-fee-changes-what-they-mean-for-your-business) retrieved 2026-06-27 4. T1 [https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/bulletins/2022/new-zealands-payment-landscapea-primer.pdf](https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/bulletins/2022/new-zealands-payment-landscapea-primer.pdf) retrieved 2026-06-27 ### W5 Payment Corridor Dynamics Confirmed confirmed 2026-06-27 NZ's principal cross-border priority is the Pacific remittance corridor (Samoa, Tonga, Fiji), among the world's most expensive, under sustained de-risking/de-banking pressure on money-transfer operators and correspondent banks. RBNZ has actively pressed banks for a risk-based (not blanket de-risk) approach and ran the Pacific Remittances Project (concluded July 2022) with the RBA/MFAT, including a regional KYC facility. Wholesale cross-border settlement uses SWIFT; ISO 20022 migration is underway. Non-bank FX/cross-border specialists (e.g. Corpay) are active. Standing sub-brief · as of 29 June 2026 207 words · last cycle 2026-09-28 #### Payment Corridor Dynamics The Reserve Bank of New Zealand ran the Pacific Remittances Project, concluded in July 2022 with the Reserve Bank of Australia, the Ministry of Foreign Affairs and Trade, and international agencies. The project addressed AML/CFT compliance to stem de-risking and developed a regional KYC facility. RBNZ states that AML laws are not an excuse to de-bank the Pacific and asks New Zealand banks to keep remittance corridors open as a strategic priority. Pacific remittance corridors are among the world's costliest and are under sustained de-risking pressure, so the RBNZ posture shapes correspondent-banking availability for money transfer operators. The cost picture is quantified by supranational data. Per Financial Stability Board 2025 cross-border KPIs, the Australia-to-Tonga corridor at 7.3% is among the Pacific's costliest, with correspondent-banking retrenchment and thin FX and liquidity constraining progress across Pacific Island countries. This sizes the corridor-cost problem motivating the New Zealand and RBNZ interventions. #### Outlook De-risking pressure persists and RBNZ is actively pressing for a risk-based approach rather than blanket withdrawal. Correspondent-banking retrenchment remains the dominant external constraint on Pacific corridor access. Note that original illicit-finance analysis on these corridors is out of WPM scope and routed to FIM; the WPM view here is the corridor-access and cost dynamic only. Periodic update · new data 2026-09-28 #### Payment Corridor Dynamics New Zealand's open-banking infrastructure and card-scheme pricing framework both saw material developments effective 1 December 2025. Open banking regulations under the Customer and Product Data Act 2025 came into force that date, requiring the four largest banks, ANZ, ASB, BNZ and Westpac NZ, to make open-banking APIs available, with Kiwibank expected to join in stages during 2026. This is a bank-specific mandate: the obligation to expose APIs falls on the largest deposit-taking institutions rather than on non-bank payment providers, reflecting the account-to-account data-access focus of the regime. The Commerce Commission's 5 March 2026 open letter reports continuing infrastructure build-out under API v2.3, with the Ministry of Business, Innovation and Employment administering the Consumer Data Right accreditation regime that governs which third parties may access customer data through these APIs. This ongoing build-out indicates the open-banking mandate is being operationalised progressively rather than having been delivered in full at the December 2025 commencement date. On the same 1 December 2025 date, the Mastercard and Visa Interchange Fee Network Standard 2025 revoked and replaced the initial interchange pricing standard set out in Schedule 1 of the Retail Payment System Act 2022. This scheme-rule supersession changes the governing framework for card-scheme interchange fees in New Zealand's retail payment system, a bank-and-scheme-relevant development distinct from, but temporally coincident with, the open-banking API mandate. #### Outlook Kiwibank's staged onboarding to the open-banking API regime during 2026 is the near-term milestone to watch, since its completion would extend mandated API availability to a fifth major bank and effectively complete first-wave open-banking coverage across New Zealand's largest deposit-taking institutions. Continued build-out reporting from the Commerce Commission under future open letters will indicate how quickly API v2.3 functionality reaches full operational maturity. **1 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### 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. **Sources and findings (4)** 1. T1 [https://www.rbnz.govt.nz/regulation-and-supervision/cross-sector-oversight/our-relationship-with-other-financial-regulators/pacific-remittances-project](https://www.rbnz.govt.nz/regulation-and-supervision/cross-sector-oversight/our-relationship-with-other-financial-regulators/pacific-remittances-project) retrieved 2026-06-27 2. T1 [https://islandsbusiness.com/commentary/pacific-banking/](https://islandsbusiness.com/commentary/pacific-banking/) retrieved 2026-06-27 3. T1 [https://www.imf.org/-/media/files/oap/oap-home/2025/tokyo-2025-session-2-cross-border-payments-tobias-v2.pdf](https://www.imf.org/-/media/files/oap/oap-home/2025/tokyo-2025-session-2-cross-border-payments-tobias-v2.pdf) retrieved 2026-06-27 4. T3 [https://cb.corpay.com/new-zealand](https://cb.corpay.com/new-zealand) retrieved 2026-06-27 ### W6 Industry Structure & Commercial Probable confirmed 2026-06-27 NZ payments is bank-anchored: Payments NZ (owned by 8 of the registered banks incl. ANZ, ASB, BNZ, Kiwibank, Westpac) governs the core clearing systems. Card acceptance is dominated by Worldline NZ (formerly Paymark, processing ~70% of in-store transactions) and Verifone as switches; Smartpay is the largest independent EFTPOS/acquiring provider. The market is consolidating under foreign ownership — Cuscal acquired Worldline NZ (Paymark) in 2026 and Shift4 acquired Smartpay (2025). The fintech sector generated ~NZD 2.6bn revenue (2023) with ~200 startups. Standing sub-brief · as of 29 June 2026 205 words · last cycle 2026-06-27 #### Industry Structure & Commercial New Zealand's core payment clearing systems are managed by Payments NZ Limited, owned by eight of New Zealand's 27 registered banks, including ANZ, ASB, BNZ, Kiwibank and Westpac; the systems transact over $7 trillion annually. Card acceptance is highly concentrated, with Worldline NZ processing around 70% of in-store transactions. This combination of bank-controlled scheme governance and a single dominant card-acceptance switch defines New Zealand's structural concentration and underpins the consolidation thesis now playing out under foreign ownership. This is fundamentally bank-PSP-anchored governance. A counterweight is emerging on the non-bank side. New Zealand's fintech sector had approximately 200 startups in 2025 and generated NZD 2.6bn in revenue in 2023, up from NZD 554m in 2013, making it the fastest-growing segment of the technology industry; digital challengers Dosh and Emerge are seeking RBNZ bank registration. This sizes the challenger opportunity counterweighting bank concentration. #### Outlook The structural story is consolidation under foreign ownership — both Worldline and Smartpay are passing to overseas owners — set against a fast-growing domestic fintech challenger base. Specific announced deals are carried in the commercial-intelligence module; the structural thesis here is the tension between concentrated bank-controlled infrastructure and an expanding non-bank challenger sector seeking direct registration and settlement access. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://multilaw.com/Multilaw/ZENTSO/BusinessGuides/Presentation/Section_Home.aspx?GuideId=2&GuideCountry=New+Zealand&GuideSection=382](https://multilaw.com/Multilaw/ZENTSO/BusinessGuides/Presentation/Section_Home.aspx?GuideId=2&GuideCountry=New+Zealand&GuideSection=382) retrieved 2026-06-27 2. T2 [https://www.globenewswire.com/news-release/2026/05/29/3303392/0/en/worldline-new-zealand-payment-activities-divestment-finalised-press-release.html](https://www.globenewswire.com/news-release/2026/05/29/3303392/0/en/worldline-new-zealand-payment-activities-divestment-finalised-press-release.html) retrieved 2026-06-27 3. T3 [https://nz.linkedin.com/company/smartpay-new-zealand-limited](https://nz.linkedin.com/company/smartpay-new-zealand-limited) retrieved 2026-06-27 4. T3 [https://fintechnews.au/119491/new-zealand/5-fintech-startups-from-new-zealand-to-watch-in-2026/](https://fintechnews.au/119491/new-zealand/5-fintech-startups-from-new-zealand-to-watch-in-2026/) retrieved 2026-06-27 ### W7 Legal & Litigation Confirmed confirmed 2026-06-27 The landmark NZ payments litigation was the Commerce Commission's 2006-2009 interchange proceedings against Visa, Mastercard and the major banks under ss.27 & 30 of the Commerce Act 1986, settled in 2009 (Visa and Mastercard agreeing to scheme-rule changes allowing surcharging and individually-set, publicly-available interchange rates). Current 'enforcement' activity is regulatory rather than courtroom: the Commerce Commission's RPSA interchange-cap decisions (final decision July 2025) and ongoing monitoring of commercial-card interchange. AML enforcement includes the DIA's SkyCity settlement (NZ$4.16m, Sept 2024). Standing sub-brief · as of 29 June 2026 181 words · last cycle 2026-06-27 #### Legal & Litigation The foundational precedent is the Commerce Commission's interchange proceedings against Visa, Mastercard and major banks under sections 27 and 30 of the Commerce Act 1986, which settled in 2009. The schemes agreed to allow merchant surcharging and individually-set, publicly-available interchange rates. This 2009 settlement is the foundational precedent enabling surcharging and transparent interchange, later superseded by the Retail Payment System Act caps. The contemporary action is regulatory rather than courtroom. The Commerce Commission's July 2025 Final Decision on interchange-fee regulation introduced a new pricing standard and an anti-avoidance 'mathematical ceiling' on issuer compensation, replacing the previous purpose test to prevent schemes offsetting interchange reductions with other fees. Commercial credit-card interchange was left uncapped pending further analysis and is under active investigation. The anti-avoidance ceiling and the open commercial-card investigation signal continued regulatory pressure on interchange beyond the headline caps. #### Outlook New Zealand's interchange story is now driven by regulatory enforcement, not litigation. The open commercial-card investigation is the live thread to watch, and the anti-avoidance ceiling demonstrates the Commission's intent to prevent fee-substitution erosion of the cap regime. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://comcom.govt.nz/news-and-media/news-and-events/archive/commerce-commission-and-mastercard-agree-to-settle-credit-card-interchange-fee-proceedings](https://comcom.govt.nz/news-and-media/news-and-events/archive/commerce-commission-and-mastercard-agree-to-settle-credit-card-interchange-fee-proceedings) retrieved 2026-06-27 2. T3 [https://www.minterellison.co.nz/insights/new-zealand-payment-system-update-interchange-fee](https://www.minterellison.co.nz/insights/new-zealand-payment-system-update-interchange-fee) retrieved 2026-06-27 3. T3 [https://b2bnews.co.nz/news/commerce-commission-targets-commercial-credit-card-interchange-fees/](https://b2bnews.co.nz/news/commerce-commission-targets-commercial-credit-card-interchange-fees/) retrieved 2026-06-27 4. T3 [https://amlwatcher.com/our-coverage/new-zealand/](https://amlwatcher.com/our-coverage/new-zealand/) retrieved 2026-06-27 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-06-27 Merchant acquiring is provided by the major banks (BNZ, ASB, ANZ, Westpac) and increasingly by independents — Smartpay began acquiring in NZ from 2023/2025, breaking the bank-only acquiring model. Acceptance economics are shaped by the RPSA interchange caps and merchant-surcharging rules: the Commerce Commission requires surcharges to be no more than the merchant's cost of accepting the payment, with a surcharge ban on in-store EFTPOS/Visa/Mastercard debit and credit payments advancing via the Retail Payment System (Ban on Merchant Surcharges) Amendment Bill. Horizon · 2026-H2 (±year) Retail Payment System (Ban on Merchant Surcharges) Amendment Bill_consultation · T1_ Standing sub-brief · as of 29 June 2026 275 words · last cycle 2026-06-27 #### Merchant Acquiring & Risk The Commerce Commission's surcharging guidance requires merchant surcharges to be transparent and no more than the merchant's cost of accepting the payment, with at least one no-surcharge payment option; non-disclosure may risk breaching the Fair Trading Act. This caps merchant surcharge revenue to cost-recovery and affects small-merchant economics and acceptance behaviour. The headline forward item is uncertain. The Retail Payment System (Ban on Merchant Surcharges) Amendment Bill — proposing to ban surcharges on in-store EFTPOS, Visa and Mastercard debit and credit payments, addressing an estimated $45-65m a year in excessive surcharging — passed first reading in September 2025 and was referred to the Finance and Expenditure Committee. As of June 2026 the Bill has stalled while the Government considers wider implications, and no changes are confirmed; surcharging remains legal under current rules. We carry this corrected status explicitly: a surcharge ban would end a material merchant revenue practice, but its stall introduces genuine forward uncertainty. On the acquiring side, Smartpay announced in early 2023 its intention to become an acquirer in New Zealand and piloted its acquiring solution with merchants, challenging the traditional bank-dominated acquiring model; micro-merchant total acceptance costs still reach 1.5-2.5% despite the roughly 0.30% domestic credit interchange cap. Independent non-bank acquiring entry breaks the bank-only model and is a structural competitive signal. #### Outlook The module's trajectory is uncertain, driven by the stalled surcharge-ban Bill with no confirmed report-back or enactment date. Merchant-acquiring operational economics, chargebacks and high-risk MCC stress remain under-indexed in current evidence. Independent acquiring entry continues to pressure the bank-dominated model even as headline interchange caps leave a gap between interchange and total micro-merchant acceptance cost. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.russellmcveagh.com/insights-news/commission-publishes-guidance-on-retail-payment-surcharging-key-takeaways-for-merchants-and-payment-service-providers/](https://www.russellmcveagh.com/insights-news/commission-publishes-guidance-on-retail-payment-surcharging-key-takeaways-for-merchants-and-payment-service-providers/) retrieved 2026-06-27 2. T1 [https://www.mbie.govt.nz/business-and-employment/business/competition-regulation-and-policy/retail-payment-systems](https://www.mbie.govt.nz/business-and-employment/business/competition-regulation-and-policy/retail-payment-systems) retrieved 2026-06-27 3. T2 [https://www.nzx.com/announcements/447985](https://www.nzx.com/announcements/447985) retrieved 2026-06-27 4. T3 [https://www.mordorintelligence.com/industry-reports/newzealand-payments-market](https://www.mordorintelligence.com/industry-reports/newzealand-payments-market) retrieved 2026-06-27 ### W9 Product Innovation & Market Development Confirmed confirmed 2026-06-27 NZ moved to regulated open banking on 1 December 2025 under the Customer and Product Data Act 2025, which designated the banking sector and incorporated Payments NZ API Centre standards (Account Information, Payment Initiation, API Security v2.3.3) by reference. Five API providers (ANZ, ASB, BNZ, Westpac, Kiwibank) must meet standardised-API timelines; nine third parties were live at go-live. Account-to-account products (BNZ's Payap, built by Centrapay) are scaling. The FMA ran a fintech regulatory sandbox pilot (six firms across tokenised assets, payments, stablecoins). Standing sub-brief · as of 29 June 2026 224 words · last cycle 2026-10-18 #### Product Innovation & Market Development The Customer and Product Data Act 2025 creates a legal right for customers to access and share data and to authorise payments. Banking-sector designation — regulated open banking — took effect on 1 December 2025, incorporating Payments NZ API Centre standards (Account Information, Payment Initiation, API Security v2.3.3) by reference. Five API providers — ANZ, ASB, BNZ, Westpac and Kiwibank — must meet standardised-API timelines, and nine third parties were live at go-live. Regulated open banking opens account-to-account payment initiation and data-sharing to third parties, the structural foundation for A2A products that could displace card rails. The early product signal is concrete. Centrapay powered the late-2025 launch of Payap, a BNZ-backed QR-based account-to-account app built on open banking that lets customers pay directly from bank accounts without card rails; it became the number-one free finance app in New Zealand's iOS App Store. This is an early demonstration of consumer-scale A2A payments riding the new open-banking rails — a competitive signal against card acceptance. #### Outlook Product innovation is escalating on the back of regulated open banking. The Payap launch validates the A2A thesis at consumer scale, and the standardised-API timelines for the five major providers will determine how quickly third parties can build competing payment-initiation products. The structural question is how far A2A displaces card rails as open-banking infrastructure matures. Periodic update · new data 2026-10-18 #### Product Innovation & Market Development Open-banking payment volumes in New Zealand continued to grow through the governance transition described under licensing and market access. In August 2026, the last full month before the Payments NZ API Centre's closure, 545,681 open-banking payments were completed, up 36 percent month-on-month, with a total value of NZ$152.9 million. This growth trajectory indicates that the underlying open-banking product -- account-to-account payment initiation built on the API Centre's technical standards -- continued to gain adoption even as its governance structure moved from an industry body to direct ministry stewardship. The scale of month-on-month growth is notable: a 36 percent increase in a single month suggests open-banking payment initiation is moving from early-adopter usage toward more mainstream transaction volume in the New Zealand market, though the data available this cycle covers only the single month of August 2026 and does not establish whether the growth rate is sustained into September and beyond the governance hand-over. #### Outlook Whether open-banking payment volume growth continues at a similar rate following the API Centre's 30 September 2026 closure and the transition to MBIE stewardship is the key product-development signal to watch in the coming periods. The cross-regulator consultation closing 27 October 2026, covering faster payments among other topics, may also shape the product roadmap for account-to-account payments in New Zealand going forward. **3 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### 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. Periodic update · new data 2026-09-14 #### 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. Periodic update · new data 2026-08-11 #### 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. **Sources and findings (4)** 1. T2 [https://www.apicentre.paymentsnz.co.nz/standards/implementation/](https://www.apicentre.paymentsnz.co.nz/standards/implementation/) retrieved 2026-06-27 2. T2 [https://www.apicentre.paymentsnz.co.nz/standards/implementation/](https://www.apicentre.paymentsnz.co.nz/standards/implementation/) retrieved 2026-06-27 3. T3 [https://fintechnews.au/119988/new-zealand/4-fintech-startups-from-new-zealand-to-have-on-your-radar-in-2026/](https://fintechnews.au/119988/new-zealand/4-fintech-startups-from-new-zealand-to-have-on-your-radar-in-2026/) retrieved 2026-06-27 4. T3 [https://blockchain.org.nz/2026/06/03/big-month-for-digital-assets-in-nz-momentum-media-and-may-policy-meetings/](https://blockchain.org.nz/2026/06/03/big-month-for-digital-assets-in-nz-momentum-media-and-may-policy-meetings/) retrieved 2026-06-27 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-06-27 NZ has NO statutory mandatory APP-fraud reimbursement regime (unlike the UK PSR model). Consumer redress runs through four approved dispute-resolution schemes, principally the Banking Ombudsman Scheme (compensation up to NZ$500,000 for direct loss). Scam reimbursement is governed by an industry-led, VOLUNTARY NZBA scam compensation scheme (in force December 2025) and an updated Code of Banking Practice; consumer advocates (Consumer NZ) criticise it as weaker than the UK regime. A Confirmation of Payee system is live and an NZ Anti-Scam Alliance has been established. Standing sub-brief · as of 29 June 2026 227 words · last cycle 2026-09-28 #### Consumer Protection & APP Fraud New Zealand has no statutory mandatory authorised-push-payment fraud reimbursement regime. Redress runs through four approved dispute-resolution schemes, principally the Banking Ombudsman, with compensation up to NZ$500,000 for direct loss. The New Zealand Bankers' Association's voluntary scam compensation scheme, in force from December 2025, broadens eligibility and pledges payment within 30 business days, but Consumer NZ criticises it as voluntary, carrying no penalties and being weaker than the UK's mandatory APP reimbursement regime. The absence of a UK-style mandatory regime materially differentiates New Zealand consumer-protection liability for banks and PSPs — this is a bank-PSP liability dynamic. Redress is nonetheless expanding at the margins. A Confirmation of Payee system is live, and an updated Code of Banking Practice provides a basis for banks to compensate customers for both authorised and unauthorised payment scam losses. The Banking Ombudsman's jurisdiction is expanding to include complaints about receiving banks whose accounts are used to receive stolen funds, alongside the new New Zealand Anti-Scam Alliance. Extending redress to receiving banks shifts scam-liability allocation in the absence of statutory mandation. #### Outlook The consumer-protection model remains voluntary and industry-led rather than statutory. The contrast with the UK's mandatory regime is the under-indexed point that will likely keep pressure on the voluntary model. The expansion of Ombudsman jurisdiction to receiving banks is the practical mechanism shifting liability allocation without legislation. Periodic update · new data 2026-09-28 #### Consumer Protection & APP Fraud Buy Now, Pay Later consumer-protection settings in New Zealand remained lighter-touch this cycle despite growing hardship evidence. Consumer NZ and FinCap research published March 2026 reports increasing BNPL-related financial hardship, concentrated in younger age groups, and argues that New Zealand lags Australia and the United Kingdom in affordability-assessment requirements for BNPL lenders. This is evidence-based advocacy research rather than a regulatory finding, but it directly informs the consumer-protection posture question for BNPL in New Zealand. Against that evidence, the Ministry for Regulation confirmed it recommended, on cost-benefit grounds, a full exemption for BNPL default fees from CCCFA lending regulations, and Cabinet agreed, rather than imposing full CCCFA lending rules on BNPL providers. This is a standing regulatory carve-out, not a new restriction, and its retention despite the Consumer NZ/FinCap hardship findings indicates New Zealand's Cabinet has, at least for now, prioritised the cost-benefit case for a lighter regulatory touch on BNPL default fees over the affordability-assessment gap identified by consumer advocates. The combination of rising hardship evidence and a retained exemption represents a persistent, rather than newly emerging, gap in New Zealand's BNPL consumer-protection framework relative to comparable jurisdictions, and is a live area of tension between consumer-advocacy findings and Cabinet's regulatory cost-benefit assessment. #### Outlook Whether accumulating hardship evidence from Consumer NZ, FinCap or other advocacy sources prompts Cabinet to revisit the BNPL default-fee exemption is the central consumer-protection question to watch for New Zealand's payments landscape. Continued divergence from Australia and UK affordability-assessment standards for BNPL lenders, absent a policy shift, would leave New Zealand consumers exposed to a comparatively lighter-touch regime during a period of rising documented hardship. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### 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. **Sources and findings (5)** 1. T1 [https://www.fma.govt.nz/consumer/everyday-finance/disputes-and-consumer-protection/](https://www.fma.govt.nz/consumer/everyday-finance/disputes-and-consumer-protection/) retrieved 2026-06-27 2. T2 [https://bankomb.org.nz/about-us/faqs](https://bankomb.org.nz/about-us/faqs) retrieved 2026-06-27 3. T3 [https://www.consumer.org.nz/articles/banks-introduce-new-compensation-measures-for-scam-victims](https://www.consumer.org.nz/articles/banks-introduce-new-compensation-measures-for-scam-victims) retrieved 2026-06-27 4. T3 [https://business.scoop.co.nz/2025/04/23/banking-ombudsman-scheme-backs-banks-stronger-consumer-protections-from-scams/](https://business.scoop.co.nz/2025/04/23/banking-ombudsman-scheme-backs-banks-stronger-consumer-protections-from-scams/) retrieved 2026-06-27 5. T2 [https://bankomb.org.nz/about-us/media-releases/2025-media-releases](https://bankomb.org.nz/about-us/media-releases/2025-media-releases) retrieved 2026-06-27 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/new-zealand/#sec-dom-D7) Probable confirmed 2026-06-27 [SENTINEL-FED] NZ's AML/CFT regime rests on the AML/CFT Act 2009 (in force 30 June 2013). Payments-relevant supervision currently splits across three supervisors — RBNZ (banks, life insurers, NBDTs), FMA (issuers/market services), and DIA (money remitters, money changers, payment service providers and DNFBPs). A major reform consolidates supervision into a SINGLE supervisor (DIA) with a new levy funding model; from 1 June 2025 customer risk-rating and online-marketplace coverage took effect. The Police FIU receives SARs/PTRs via goAML. Horizon · 2026-H2 (±year) AML/CFT single-supervisor (DIA) consolidation and levy model_in_force_pending · T3_ Standing sub-brief · as of 29 June 2026 237 words · last cycle 2026-06-27 #### AML/CFT & Financial Crime (Sentinel-fed) This module is sourced from the Sentinel feed; the intelligence below is carried as provenance, and original illicit-finance analysis is out of WPM scope and routed to FIM. Per the Sentinel feed, New Zealand's AML/CFT framework rests on the AML/CFT Act 2009 and is currently supervised by three agencies — RBNZ, FMA and the Department of Internal Affairs. A reform programme consolidates the DIA as the single AML/CFT supervisor with a new levy funding model, and from 1 June 2025 a customer risk-rating requirement and online-marketplace coverage took effect. The regime captures approximately 7,000 New Zealand businesses; the Police Financial Intelligence Unit receives SAR, PTR and border-cash reports via goAML, and the Ministry of Justice coordinates FATF and APG relationships. Source: Sentinel feed (Minter Ellison reporting on the AML/CFT update wave). For payments specifically, the single-supervisor consolidation under DIA changes the AML supervisory touchpoint and levy burden for payments reporting entities — a structural compliance shift, and the bank-versus-non-bank supervision-gap reform is the material development. This intelligence is entirely Sentinel-fed with no independent WPM corroboration of the timeline or levy details. #### Outlook The single-supervisor consolidation and new levy model are in force pending full implementation. WPM tracks only the payments-compliance touchpoint and supervisory-structure dimension; any sanctions, illicit-finance or de-risking analysis belongs to FIM. The supervision-gap reform is the development to monitor for its effect on the AML touchpoint of payments reporting entities. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 sentinel://https://www.dia.govt.nz/Regulatory-Stewardship---AML-CFT 2. T? FIM (sentinel.gi) per-JID baseline profile — New Zealand — AML/CFT Act 2009 (extended 2018 to all DNFBP sectors) with three supervisors — RBNZ, FMA, DIA — and NZ Police FIU (NZPFIU). Strong ML prosecution/asset-forfeiture record but historically weak targeted financial sanctions implementation and beneficial ownership transparency; in FATF enhanced follow-up since 2021 MER. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: national divergence ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-06-27 Open banking live 1 Dec 2025 under CPD Act 2025; RBNZ March-2025 ESAS access expansion to non-bank entities in two phases. Standing sub-brief · as of 29 June 2026 205 words · last cycle 2026-08-06 #### Correspondent Banking, Settlement & Access The analytical spine of this module is the bank-versus-non-bank access asymmetry, and the live development narrows it. In March 2025 the Reserve Bank of New Zealand completed a comprehensive review of Exchange Settlement Account System access and revised its criteria to expand eligibility to non-bank entities in two phases — first licensed non-bank deposit takers, then PSPs, overseas deposit takers and designated FMI operators. Holding an ESAS account is a prerequisite to participating in New Zealand's BECS and SBI clearing systems, so opening central-bank settlement-account access to non-bank PSPs is a structural market-access shift that reduces dependence on bank sponsors for clearing participation. This directly addresses the bank-PSP versus non-bank-PI/EMI access gap that historically defined the module. Correspondent-banking de-risking remains the dominant external pressure, most acutely on Pacific corridors. The access-widening at the domestic settlement layer therefore sits alongside continued retrenchment at the cross-border correspondent layer. #### Outlook The trajectory is opening at the domestic settlement-access level while remaining under pressure at the cross-border correspondent level. The phased ESAS expansion will determine how quickly non-bank PSPs can participate directly in clearing rather than relying on bank sponsorship. The Pacific de-risking dynamic, addressed in the corridor module, remains the principal external constraint. Periodic update · new data 2026-08-11 #### Correspondent Banking, Settlement & Access New Zealand's bank resolution and loss-absorption architecture is built on a bail-in mechanism that sits at the centre of the Deposit Takers Act 2023. Licensed deposit takers of relevant scale must hold at least NZD1 billion in convertible debt securities that the Reserve Bank can trigger for conversion into ordinary shares, providing a loss-absorption buffer ahead of any recourse to public funds; this operates alongside a Depositor Compensation Scheme covering deposits up to NZD100,000. The structural spine of this module is the asymmetry between how bank-scale institutions access bail-in-backed resolution mechanisms and the settlement and access arrangements available to non-bank participants, an asymmetry the current consultation cycle does not resolve. RBNZ has opened a further crisis-preparedness consultation targeting orderly resolution of licensed deposit takers without recourse to public funds, submissions due 11 September 2026. #### Outlook Crisis-preparedness standards arising from this consultation are not expected to be issued until 2028, with effect from 2029, meaning the bail-in and resolution framework's practical mechanics remain provisional for an extended period. The September 2026 consultation close is the near-term marker for how these mechanics will be refined. **Sources and findings (4)** 1. T1 [https://www.rbnz.govt.nz/money-and-cash/future-of-money/payments](https://www.rbnz.govt.nz/money-and-cash/future-of-money/payments) retrieved 2026-06-27 2. T3 [https://www.minterellison.co.nz/insights/rbnz-expands-access-to-the-settlement-accounts](https://www.minterellison.co.nz/insights/rbnz-expands-access-to-the-settlement-accounts) retrieved 2026-06-27 3. T1 [https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/bulletins/2022/new-zealands-payment-landscapea-primer.pdf](https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/bulletins/2022/new-zealands-payment-landscapea-primer.pdf) retrieved 2026-06-27 4. T1 [https://islandsbusiness.com/commentary/pacific-banking/](https://islandsbusiness.com/commentary/pacific-banking/) retrieved 2026-06-27 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-06-27 Inbound consolidation: Shift4/Smartpay completed (~NZ$296.4m); Cuscal/Paymark (A$27m/c.€17m) PENDING completion (French Works Council + put option) expected by 30 June 2026, not completed at 27 June 2026; Klarna/Laybuy BNPL consolidation. Horizon · 2026-06 (±quarter) Cuscal/Paymark (Worldline NZ) acquisition completion_in_force_pending · T3_ Standing sub-brief · as of 29 June 2026 303 words · last cycle 2026-08-06 #### Commercial Intelligence (M&A, Investment & Product) Three commercial events define the module. First, Shift4 agreed in June 2025 to acquire Smartpay (NZX:SPY, ASX:SMP) for approximately NZ$296.4m (US$180m, a 46.5% premium to 90-day VWAP, NZ$1.20 per share), extending into the ANZ market and acquiring Smartpay's 40,000-plus merchants; the deal was expected to close in Q4 2025 and is carried as completed. This is an inbound US acquisition of the largest independent New Zealand EFTPOS and acquiring provider — a key consolidation event under foreign ownership. Second, Cuscal Limited (ASX:CCL) agreed to acquire Worldline's New Zealand payment activities (Paymark) for an enterprise value of around €17m (A$27m), reviving the Paymark brand. This transaction is subject to completion conditions — a mandatory French Works Council consultation and Worldline exercising a put option — with completion expected by 30 June 2026; as of 27 June 2026 the acquisition had not yet completed. We flag this status correction explicitly: an earlier headline framed the deal as finalised, but Cuscal's own ASX disclosure confirms completion conditions were outstanding at the run date, so the event status is pending, not completed. The target is New Zealand's dominant card-acceptance switch (around 70% in-store). Third, Klarna's 2024 acquisition of Laybuy consolidated approximately 500,000 local BNPL accounts under a single underwriting engine; the deal value was not publicly disclosed. New Zealand BNPL outstandings were reported at NZD 2.7bn in 2026 despite mandatory credit checks from September 2024, signalling a maturing BNPL segment. #### Outlook The active inbound-consolidation theme continues. Shift4/Smartpay is completed and Klarna/Laybuy is completed, but the Cuscal/Paymark completion remains the live item — its closing depends on the French Works Council consultation and put option, with the run-date status carried as pending and requiring post-30-June-2026 confirmation. The completion of the Cuscal/Paymark deal would concentrate New Zealand's dominant card-acceptance switch under Australian ownership. Periodic update · new data 2026-08-11 #### Commercial Intelligence & Fintech The Financial Markets Authority announced on 12 March 2026 that it plans to expand its regulatory sandbox into an on-ramp/restricted-licence model, with four of six pilot firms having identified a viable market pathway. This is a discrete commercial-access event distinct from the FMA's broader thematic fintech policy stance: it signals a concrete licensing product taking shape from the sandbox pilot rather than a general regulatory-innovation posture. The sandbox expansion runs concurrently with the FMA's first stablecoin product determination for NZDD, which was itself announced as part of the same sandbox-related communications, indicating that the sandbox has already produced at least one substantive regulatory output ahead of the on-ramp licence model's formal launch, amount not publicly disclosed. #### Outlook Which of the four pathway-identified pilot firms convert into fully licensed on-ramp entrants, and on what timeline, is the concrete commercial development to track next. Any additional product determinations emerging from the sandbox pilot process are also relevant to this module rather than to W2 alone, where the determination itself concerns product classification. **Sources and findings (5)** 1. T2 [https://investors.shift4.com/news-events/press-releases/detail/265/shift4-to-acquire-australian-payments-leader-smartpay](https://investors.shift4.com/news-events/press-releases/detail/265/shift4-to-acquire-australian-payments-leader-smartpay) retrieved 2026-06-27 2. T2 [https://www.globenewswire.com/news-release/2026/05/29/3303392/0/en/worldline-new-zealand-payment-activities-divestment-finalised-press-release.html](https://www.globenewswire.com/news-release/2026/05/29/3303392/0/en/worldline-new-zealand-payment-activities-divestment-finalised-press-release.html) retrieved 2026-06-27 3. T3 [https://www.interest.co.nz/banking/138093/australias-cuscal-acquiring-electronic-payments-processor-worldline-new-zealand-and](https://www.interest.co.nz/banking/138093/australias-cuscal-acquiring-electronic-payments-processor-worldline-new-zealand-and) retrieved 2026-06-27 4. T3 [https://fintechnews.au/119491/new-zealand/5-fintech-startups-from-new-zealand-to-watch-in-2026/](https://fintechnews.au/119491/new-zealand/5-fintech-startups-from-new-zealand-to-watch-in-2026/) retrieved 2026-06-27 5. T3 [https://www.mordorintelligence.com/industry-reports/newzealand-payments-market](https://www.mordorintelligence.com/industry-reports/newzealand-payments-market) retrieved 2026-06-27 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for New Zealand| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 58 finding(s), 123 source(s) in the cumulative register. **Audit trail** Machine check Challenged on 6 Oct 2026: upheld (25 confirmed against the cited source; 52 could not be checked). An automated, adversarial test run by a second model; no person has assessed the result. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).