Submission on RBNZ consultation on the prudential levy
19 Oct 2026
Payments NZ has made a submission on the Reserve Bank of New Zealand – Te Pūtea Matua consultation on the proposed prudential levy.
The submission focuses on the proposed treatment of designated financial market infrastructures and, in particular, Payments NZ as the operator of the High Value Clearing System. Payments NZ supports effective prudential supervision, while recommending that the levy framework better reflect the materially different functions, operating models, risks, benefits and supervisory requirements of different financial market infrastructures.
Payments NZ recommends a differentiated and proportionate approach that:
- aligns levy liability with risk, benefit and supervisory effort
- recognises existing participant-funded governance, risk management and assurance arrangements
- identifies and minimises overlapping cost recovery
- maintains a reasonable relationship between levy liability and the nature and level of supervision required
- retains the option of partial rather than full industry cost recovery where prudential supervision provides material wider public benefit.
The submission also highlights that Payments NZ’s role as a rules and governance operator differs materially from an operator that owns or directly operates transaction-processing or settlement infrastructure.