Submission on MBIE consultation on delegation requirements and professional trust accounts in regulated open banking
19 Jun 2026
Payments NZ has submitted feedback to the Ministry of Business, Innovation and Employment Hīkina Whakatutuki (MBIE) on its consultation on delegation requirements and the treatment of professional trust accounts in regulated open banking.
We support the objective of enabling open banking for business customers. Our submission focuses on ensuring regulation supports customer outcomes, ecosystem growth and long-term adoption, while avoiding unnecessary complexity and implementation costs.
Key points from our submission
- Regulation should focus on outcomes rather than prescribing how banks design internal authority, entitlement and identity-validation systems.
- Open banking should build on existing banking authority frameworks, avoiding separate permission structures that may increase complexity, customer friction and delivery risk.
- Business customer needs should drive prioritisation, with regulatory effort focused on the capabilities most likely to improve customer value, increase uptake and support broader ecosystem outcomes.
- A clear long-term strategy and roadmap for open banking and open data is needed to provide certainty on future priorities, desired outcomes and the sequencing of reform.
Professional trust accounts
Payments NZ supports professional trust accounts ultimately being included within regulated open banking. However, we recommend a phased approach that brings these accounts into scope after 1 June 2027.
This reflects implementation complexity, unresolved standards questions, privacy considerations and the opportunity cost of diverting effort from higher-priority business capabilities.
Priority for business open banking
Our submission highlights multi-authorisation for payments as the highest-impact next step for business open banking, with the potential to deliver broader value for business customers and support greater adoption across the ecosystem.
Looking ahead
Payments NZ supports a joined-up approach to open banking and open data that promotes innovation, interoperability, trust and customer value. We believe greater clarity on long-term outcomes, supported by a roadmap for future reform, will help focus effort on the areas most likely to deliver value for businesses and the wider ecosystem.