Submission to RBNZ on the High Value Clearing Systems designation proposal
23 Oct 2025
We recently made a submission to the Reserve Bank of New Zealand - Te Pūtea Matua (RBNZ) on its proposal to designate the High Value Clearing System (HVCS) under the Financial Market Infrastructures Act 2021 (FMI Act).
Our position
We do not support the proposed designation. In our view, the Reserve Bank does not have a clear legal basis to designate HVCS under the FMI Act. Even if such a basis were established, we do not believe there are sound policy reasons to justify the action.
The nature of HVCS
Payments NZ is a rules body only – we do not own or operate payments infrastructure. The system resilience that matters relates directly to SWIFT and the Reserve Bank’s Exchange Settlement Account System (ESAS). ESAS is already designated under the FMI Act and, because our rules require settlement to take place in ESAS, settlement finality is assured. Designating our rules would therefore not enhance system stability or resilience.
Practical implications
We are also concerned about the practical impacts of designation — particularly the additional cost, complexity, and potential inefficiency it may introduce for system participants and the wider industry.
Our view
We believe the existing combination of the Reserve Bank’s oversight, the designated status of ESAS and Payments NZ’s robust governance framework provide all the necessary legal certainty and operational resilience in HVCS, without the need for formal designation.