AI Forum Submission: Embedding Trust, Fairness and Global Alignment in New Zealand’s Digital Identity Framework

Submission by AI Forum of New Zealand to the Department of Internal Affairs

The AI Forum of New Zealand has submitted feedback on the Digital Identity Services Trust Framework (DISTF) Phase 2 Regulations, expressing strong support for the Department’s preferred options while recommending enhancements to ensure the system remains flexible, fair, and internationally aligned.

Key Position

The AI Forum supports the goal of building a trusted and consistent digital identity framework for Aotearoa. The submission emphasises that the system must balance security and assurance with accessibility, fairness, and proportionality – especially for small and medium-sized providers.

Key Recommendations

The submission focuses on three main areas:

• Accreditation Renewal – The Forum supports a standardised renewal pathway for consistency but suggests it should be complemented by continuous monitoring and proportional oversight. This would reduce compliance burdens, particularly for SMEs, while keeping pace with international standards such as ISO/IEC 42001:2023.
• Levels of Assurance – The Forum endorses a five-level assurance model, including a distinct “standard plus” level for biometrics. It also recommends embedding fairness, inclusivity and interoperability as explicit assurance values to address risks of bias in biometric systems and ensure accessibility across all users.
• Reporting Dates – The Forum supports moving reporting to March and September but encourages piloting structured, machine-readable submissions (e.g. XML or JSON) to streamline compliance and align with emerging global practices in digital governance.

Global Best Practice and Risk Management

The submission notes that other jurisdictions (such as Australia, the UK and the EU) are moving towards risk-based, continuous monitoring models supported by RegTech tools. The Forum recommends a hybrid model that maintains a standard baseline but allows targeted oversight for higher-risk providers, ensuring both rigour and proportionality.

The Bigger Picture

The AI Forum, a member of the NZTech Group, represents industry, academia and government working together to advance the responsible and inclusive adoption of AI in New Zealand. By aligning the digital identity framework with international standards and embedding principles of fairness and inclusivity, the submission highlights the opportunity for New Zealand to strengthen public trust, global interoperability, and economic participation in digital trade.

Moving Forward

The AI Forum’s submission underlines the importance of adopting a living framework – one that remains adaptable to evolving technologies while ensuring trust and accessibility for all users. By embedding international best practice and supporting proportionate regulation, New Zealand can build a digital identity system that empowers innovation while protecting people.