Submission on the payment services regulation
6 Jul 2026
Payments NZ has submitted feedback to the Ministry of Business, Innovation and Employment Hīkina Whakatutuki (MBIE) on its discussion document on payment services regulation.
We support the intent to improve clarity, consistency and outcomes across the payments ecosystem. Our submission focuses on the need for a more coherent and proportionate regulatory framework that reflects how modern payment services operate, while supporting trust, innovation and system-wide efficiency.
Key points from our submission
- The current framework is fragmented and incomplete
Payment service providers face overlapping requirements in some areas, while important gaps remain in others.
- A proportionate licensing regime for payment service providers is needed
This would provide a clearer baseline for trust, accountability, governance and security.
- Regulation should simplify, not add complexity
Reform should align and streamline existing settings, rather than layering new requirements onto an already complex framework.
- A system-wide approach is essential
Payment services operate across a connected value chain, from customer-facing services through to infrastructure, rules and standards.
- Clear distinction between regulation and industry rules must be maintained
Regulation should set outcomes and protections, while industry manages operational and technical delivery.
- Regulation should be activity-based and proportionate to risk
Providers undertaking similar activities and presenting similar risks should face similar requirements.
Supporting access, trust and system outcomes
Our submission highlights how a licensing regime could support more efficient participation in payment systems by providing a common baseline that infrastructure operators can rely on.
This would help reduce duplication in access processes, strengthen confidence across the ecosystem and support broader participation over time.
Looking ahead
Payments NZ supports a coordinated and system-wide approach to reform, aligned with related work such as open banking, payment system modernisation and financial market infrastructure oversight.
Greater clarity on the overall direction of payment system reform – including roles, responsibilities and sequencing – will be critical to achieving coherent, long-term outcomes.
Read the full submission