Digital Service Providers Australia New Zealand (DSPANZ) has lodged a submission on the Employment Leave Bill with the NZ Parliament Education and Workforce Committee.
While broadly supportive of the intent of the Bill, we have highlighted that the success of the reform depends on whether it can be consistently implemented across systems in practice without creating unnecessary complexity or risk.
Proposed Changes
The Employment Leave Bill proposes a significant reform of how employee leave is calculated, classified, and administered in Aotearoa New Zealand. It aims to address long-standing issues with the Holidays Act by introducing a more structured and consistent framework.
Key changes:
- Hours-based leave accrual
- Single rate of pay for leave calculations
- Rules for determining entitlements, including otherwise working days
While these are intended to improve clarity and consistency, the Bill shifts complexity from calculation to data, classification, and system design. This introduces new dependencies and implementation risk across payroll and workforce systems.
Why This Matters
For DSPs in New Zealand, the Bill introduces significant changes to how leave is calculated, classified, recorded and reported across payroll systems.
These changes require system updates, new data structures, and coordinated changes across payroll, HR, and rostering systems. Without clear guidance and workable design, there is a risk of inconsistent implementation, increased compliance costs, and reliance on manual workarounds.
Our Position
DSPANZ is broadly supportive of the Bill intent and the move toward a more structured framework for employment leave. However, the key challenge as always is how the policy intent will transition to implementation within DSP products.
A workable outcome relies on:
- clear and deterministic rules that can be consistently applied across systems
- detailed guidance to support consistent interpretation and configuration
- alignment with real-world system capability and constraints
- phased, readiness-based implementation that reflects both system and employer transition requirements
- ongoing engagement with DSPs to support design, testing and implementation.
DSPANZ will continue to engage with MBIE and key stakeholders and advocate for the development of a framework that is both conceptually sound and operationally workable.
Members can read our full submission here.