DSPANZ provided a submission to Inland Revenue on the proposed legislative changes for intermediaries on 17 June 2026.
This submission supported a framework that is proportionate, technology-neutral and commercially workable, while highlighting areas where further clarification, co-design and transitional relief would help support successful implementation.
Our core responses included:
- We supported a single DSP category function-specific obligations through terms of use, not separate statutory sub-categories.
- We supported automatic transition for existing DSPs: no full re-application.
- We supported the data consumer category, designed to align with the Customer and Product Data Act 2025.
- We supported further development of the tax crediting agent model, with safe harbours and without requiring DSPs to hold client funds.
- We recommended the cost-benefit test be legislated as a whole-of-system assessment with published criteria.
- We recommended proportionate, transparent standards accessible to smaller and emerging providers.
- We recommended direct co-design engagement with Maori on accreditation, consent and data sharing design.
Read more in the full submission.