NZTech Submission: Ensuring a Future-Proof Digital Identity Framework for Aotearoa

Submission by NZTech to the Department of Internal Affairs

NZTech has lodged its submission on the Digital Identity Services Trust Framework (DISTF) Phase 2 Regulations, welcoming the opportunity to strengthen New Zealand’s digital identity system. The submission supports the direction of the regulations while highlighting areas to ensure they remain relevant, fair, and internationally aligned.

Key Position

NZTech supports the focus on creating a trusted, consistent, and globally interoperable digital identity system. The organisation emphasises that Phase 2 regulations must provide businesses and users with certainty, while remaining flexible enough to adapt as technologies continue to evolve.

Key Recommendations

The submission highlights three priority areas for improvement:

• Accreditation Renewal – NZTech supports a consistent renewal pathway, but recommends proportionality measures for smaller providers, as well as mechanisms for interim oversight between renewal periods.
• Levels of Assurance – NZTech supports the inclusion of levels of assurance, with five levels as proposed. However, it recommends regular reviews (e.g. every three years) to ensure they keep pace with global frameworks and technological change.
• Reporting Dates – NZTech supports shifting reporting to March and September, reducing administrative burden and easing compliance by avoiding government year-end peaks.

The Bigger Picture

As New Zealand’s united technology industry body, NZTech represents over 2,500 organisations across startups, multinationals, education, and government – employing more than 10 percent of the national workforce. The tech sector contributes around $22 billion to GDP and is New Zealand’s third-largest export sector, with software exports alone growing more than 20 percent annually.

Ensuring our digital identity framework is relevant, resilient, and globally interoperable will not only protect New Zealanders but also strengthen digital trade and support innovation across the economy.

Moving Forward

NZTech’s submission underscores its commitment to working with government and industry to ensure Aotearoa’s digital identity system meets the highest international standards while reflecting local needs. By reinforcing trust, consistency, and alignment with global best practice, the framework has the potential to establish New Zealand as a leader in safe and trusted digital identity.