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The Association of Digital Service Providers Australia New Zealand (DSPANZ) writes this statement on behalf of the New Zealand Digital Advisory Group - Payroll Working Group to raise concerns about the proposed amendments to the Holidays Act (the Act) and the importance of working alongside payroll software providers to ensure changes can be operationalised. 

The Holidays Act Review set out to reduce ambiguity and make it easier for employees to understand their entitlements. However, the proposed amendments are expected to create an even more complex Act, leading to an administrative and compliance burden for payroll software providers, payroll practitioners and employers. 

With payroll software providers playing a critical role in facilitating employer compliance with the Act, it is crucial that the Ministry of Business, Innovation and Employment (MBIE) works alongside and supports payroll software providers to ensure a smooth implementation and transition to an updated Act. 

The Holidays Act is already a complex Act. There is currently no avenue for payroll software providers to seek clarity at the technical level we require. DSPANZ recommends that MBIE establish a relationship manager for payroll software providers, similar to Inland Revenue's model, that would provide:

  • Assistance during the upcoming changes to the Act and ongoing support for technical questions and interpretations; and
  • Opportunities for early and ongoing engagement on changes to employee payment terms and conditions to ensure mutually beneficial outcomes and better compliance. 

Payroll software providers also recommend that the Act allow MBIE to give interpretations similar to how Inland Revenue can provide operational instructions. While these interpretations could change based on the legislation, it would enable MBIE to provide a more concrete view that payroll software providers can leverage to meet the intent of certain sections within the Act. 

DSPANZ recognises that the change in government may have resulted in a different view on the Holidays Act Review to date. Payroll software providers would welcome the opportunity to highlight our concerns with the existing Taskforce recommendations and add our views on any new or amended proposals. 

In summary, DSPANZ would appreciate any actions to facilitate MBIE establishing a relationship manager for payroll software providers and ensuring we are actively involved in legislative changes impacting payroll. This level of engagement will lead to better outcomes for all impacted parties and ensure that new policies are successfully operationalised. 

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