DIGITAL PUBLIC INFRASTRUCTURE

Digital public infrastructure is not a technical solution. It is a mechanism through which the state governs society, collecting data, mediating access, and configuring how it sees its citizens and how citizens interact with the state. When infrastructure operates at that level of social consequence, constitutional obligations are not optional extras. They are the price of legitimacy. (Pandey V. 2026) [1]

PSGRNZ published Stepping Back from the Brink: The Programmable Ledger. Four democratic risks that arise when Digital IDs are coupled to Central Bank Digital Currencies in 2024. In the two years since this paper was published, it is difficult to identify what progress has been made, what the Reserve Bank of New Zealand (RBNZ) - new Zealand's central bank, is currently doing and whether Parliament is adequately informed.

As part of wider reforms, the RBNZ have released a consultation ‘Modernising New Zealand’s retail payment system’, which closes October 27. It is accompanied by an Issues paper (August 2026).

It is increasingly evident that the RBNZ intends to oversee the reform of New Zealand's digital payments infrastructure. The problem is that this work does not stand alone. It directly intersects with the RBNZ's CBDC work programme and with the development of a much broader, increasingly interconnected digital public infrastructure.

The RBNZ, Treasury, Public Service Commission (PSC), Department of Internal Affairs (DIA) and Ministry of Business, Innovation and Employment (MBIE) are all aware of this wider context and the government's role in coordinating 'the delivery of core digital public infrastructure – digital ID, open data and modern payments'. Modern retail payments may increasingly intersect with digital identity, data-sharing systems and other public and private digital infrastructure. This raises fundamental questions about whether, how and on what terms ordinary New Zealanders may be drawn into a broader interoperable digital architecture.

These are not merely technical decisions about how payments should work. They are choices about institutional power, individual autonomy and the purposes for which interconnected infrastructure may be used, with consequences that could endure for decades.

Those choices require democratic and political judgement. They should not be determined by a central bank.

The RBNZ's Issues paper (August 2026) does not address that much broader context where a digital public infrastructure can become a powerful tool for the oversight of citizens.

Yet the RBNZ has now assumed leadership of a major national reform without demonstrating that it has undertaken a deep comparative examination of overseas jurisdictions. Instead, its international comparisons largely present the visible outcomes of selected systems, without adequately examining the institutional, legal and constitutional arrangements that produced them, or the longer-term consequences of those arrangements.

Any global comparisons should have extended to ownership, operation, access, rule-setting, transaction visibility, technological dependency, contingency capability and the capacity of genuinely independent alternatives to survive. This requires examining a wider range of mature systems, including Japan, South Korea, Norway, Finland and Switzerland, alongside jurisdictions such as Thailand, Malaysia and the Philippines that provide useful evidence concerning bank-owned infrastructure, central-bank oversight, common utilities, consolidation, identity integration and competition.

In addition, the RBNZ's proposal that India's UPI be considered as a potential model for New Zealand warrants far greater scrutiny than is evident from the information publicly released to the public to date. The process lacks transparency and provides the public with little basis on which to hold the RBNZ accountable.

What is also concerning, and questionable, is the evidence in the Statements of Performance Expectations (2025/2026 and 2026/27) that the RBNZ have folded their CBDC work programme into a secretive expense that is excluded from the funding agreement with Treasury and folded into a larger 'capital projects' expense. The RBNZ's Statement of Intent 2024-2028 show that it is clearly progressing a CBDC investigation, but there is no evidence that the RBNZ is considering the broader constitutional and democratic issues that PSGRNZ highlighted that were of great public concern in the 2024 Stepping Back from the Brink paper.

Because of the gaps in RBNZ policy papers, J.R. Bruning has sent in an Official Information Act request: Real-Time Payments Modernisation: International Evidence, Governance, Plurality and Infrastructure.

These are broader constitutional and political issues, however, they are not transparently discussed by the RBNZ and the public are not granted a meaningful opportunity to address them. As we discuss below, the RBNZ has full knowledge that it could clip CBDCs as a rail on a future modernised payments system. This conflict-of-interest where the RBNZ would secure more powers from the very policy it is consulting upon and developing, is not declared.

The Sept-Oct 2026 Consultation Issues paper (August 2026) only briefly references CBDCs as a feature of a modern payments system. The RBNZ does not provide the opportunity for the public to choose to respond to the potential to integrate 'digital cash' or CBDCs into the future payments system. The RBNZ do not conduct surveys to evaluate the extent of public concern for Central Banks taking on such powers, nor the concern expressed by constitutional and public law experts.

The RBNZ is well aware of this wider context, as its September 18 2025 proposal to the Minister of Finance demonstrates

Yet in the Issues Paper, the public is largely presented with technical questions within a narrowly framed consultation.

The relevant policy question is not simply whether the Reserve Bank or the banking industry should control new infrastructure, but what institutional arrangements can steward an increasingly indispensable national payment system in the public interest over decades.

The Issues Paper calls for a ‘system-wide, future-focused view’, but applies that concept principally to technological capability, interoperability, integration and adaptability. A genuinely system-wide and long-term perspective must also consider the institutional architecture through which power over critical payment infrastructure will be exercised.

The Issues Paper repeatedly draws attention to a ‘fragmented regulatory network’ and a ‘lack of clear leadership’, without adequately considering the benefits that institutional separation may provide, or the corresponding importance of governance, transparency and independent oversight.

More fundamentally, the Issues Paper does not demonstrate that questions of public law, governance and the constitutional implications of digital public infrastructure have been subjected to comparable expert scrutiny.

The relevant future-facing question is therefore not simply whether New Zealand's payment infrastructure can accommodate the next technology, but whether its governance arrangements will continue to protect resilience, contestability, national autonomy and democratic accountability as that infrastructure becomes increasingly indispensable.

Modern payment systems unquestionably require central-bank expertise. But technical expertise should not quietly expand into authority to determine questions that are fundamentally political: who controls critical national infrastructure, how institutional power is distributed, how much informational integration citizens should tolerate, which independent alternatives should be preserved, and what dependencies New Zealand should accept. Those questions belong within democratic government. The central bank should inform them, not inherit them.

The real choice (for example) is not simply MBIE or Payments NZ or RBNZ leadership. There is a spectrum of institutional possibilities: user-owned mutual infrastructure, dispersed bank ownership, independent statutory bodies, industry infrastructure subject to strong public oversight, central-bank settlement separated from retail operations, and combinations of these.

Central banks are principally responsible for monetary and financial stability functions, not for determining wider political policy. How New Zealand modernises real-time payments beyond the older EFTPOS system involves choices about the future architecture of critical national infrastructure. Those are political and institutional choices, not merely central-banking questions.

The RBNZ is also in the unusual position of being largely in charge of its own budget. Unlike ordinary government departments, its operating expenditure is not authorised through Parliament's annual appropriations process. Instead, the Bank and the Minister of Finance agree a multi-year Funding Agreement that sets expenditure limits, while the RBNZ determines how those resources are deployed within its statutory functions.

Parliament does not vote annually to approve that administrative budget in the way it does departmental appropriations.

This gives the RBNZ considerable institutional and resourcing autonomy. If it decides to develop and lead a major policy programme, it does not operate under precisely the same budgetary constraints and parliamentary controls as an ordinary government agency.

If the RBNZ assumes leadership of a major policy programme, the usual mechanisms of ministerial, departmental and parliamentary control do not necessarily operate in the same way. The RBNZ proposed that it lead consultation on real-time payments while also being aware that future payment infrastructure could intersect with other developments it was actively involve with, including potential CBDCs - central bank digital cash.

The public should therefore have been asked a much broader question: Has the RBNZ undertaken any whole-of-architecture assessment of its comparator jurisdictions, examining not simply payment functionality but the constitutional and public-law consequences of interoperability between payments, digital identity, biometrics and government or private-sector data, including purpose limitation, persistent identifiers, cross-domain linkage, institutional concentration, citizen visibility, function creep and independent whole-stack oversight?

COMPARATOR COUNTRIES - LIMITED GRASP OF THE INTERNATIONAL EVIDENCE

RBNZ appears to have selected comparator jurisdictions primarily to examine payment functionality and modernisation pathways, rather than jurisdictions that illuminate the constitutional choices created by critical digital infrastructure. Concerningly, the comparator jurisdictions are not discussed at length but merely assembled into brief summary tables that fail to see the broader context of a countries application of a system.

The international analysis disclosed by RBNZ is strikingly limited. Its principal comparators are Australia, Singapore, Sweden, the United Kingdom and Canada, with Brazil and India included in its broader fast-payments comparison. RBNZ uses these jurisdictions to support the proposition that payment-system modernisation is generally led or strongly steered by governments or central banks.

An earlier September 2025 International Comparisons of Fast Payments Systems was similarly notably narrow, covering Australia, Brazil, India, the EU, UK and Singapore. Complex institutional arrangements are compressed into descriptions such as ‘industry-led’, ‘Central Bank of Brazil’, ‘NPCI under Reserve Bank of India oversight’ and ‘European Central Bank’. This comparison was subsequently used to support the proposition that ‘Central banks have generally driven similar initiatives overseas’[22], contributing to RBNZ's conclusion that it was ‘best positioned’ to lead New Zealand's modernisation. [23]

Such classifications obscure the fact that central-bank settlement, oversight, strategic leadership, ownership and operation are distinct functions. Likewise, consumer-facing competition does not establish infrastructural plurality: hundreds of banks or payment applications may ultimately depend upon one common switch, addressing system or settlement infrastructure.If international institutions define what constitutes a ‘modern’ payment system, jurisdictions implementing those frameworks are then selected as comparators, and those comparators are subsequently cited as evidence of international best practice, alternative institutional arrangements can disappear from consideration without ever being expressly rejected.

September 18 2025 RBNZ request that Nicola Willis endorse the RBNZ to lead the development of a strategic proposal on payments modernisation. Appendix 1. (page 18/21)
August 18 2026. RBNZ Issues Paper. Modernising New Zealand’s Retail Payment System. Tables 1 and 2

The countries have only been integrated into lists and charts, the broader constitutional and democratic implications of different payment systems, published journal literature discussing the relative merits of the different systems, and how they potentially integrate into the digital public infrastructure, and how this interacts with the capacity of the individual citizen to consent or not consent and hence, to individual rights, have not been considered.

A broader comparison would have included Germany for informational self-determination and proportionality, Estonia for distributed and citizen-auditable digital architecture, South Korea for statutory separation of institutional powers and legislative accountability, Norway for national control and operational autonomy, and Japan for the treatment of payments as essential social infrastructure. But it hasn't.

Co-ordination – integrative cooperation does not require institutional concentration: international experience demonstrates that common infrastructure can coexist with dispersed ownership, independent governance, central-bank settlement, regulatory oversight and competition at other layers. The charts provided by the RBNZ in the Issues Paper - limit consideration to discretely considered issues in the comparator countries - RBNZ does not look at how other countries have separation of powers but arrange governance in such a way that everyone must work together.

The OIA request sought to understand whether any deeper exploration underlies the RBNZ's limited policy framing, comparator selection and emerging governance options. It asks how ownership, institutional separation, infrastructural plurality, resilience, digital identity, data linkage and democratic accountability have been assessed before the range of options presented to Ministers and the public is narrowed.

2020-2024 RBNZ DEVELOPMENT OF A BUSINESS CASE FOR CENTRAL BANK DIGITAL CURRENCIES (CBDCs)

The RBNZ have confusingly and misleadingly, elected to communicate CBDCs in the language of ‘digital cash’.

‘Since 2021 we have been exploring the role of a retail Central Bank Digital Currency or (we call it Digital Cash’).[2]

It is easy to conflate ‘digital cash’ with the digital cash held in citizens retail bank accounts. The RBNZ use the term CBDCs when they discuss CBDCs in policy or when they communicate with other banks. However, much is happening, it is just not being clearly disclosed to the public or, PSGRNZ suspect, from the absence of information on the public record, to members of Parliament.

2025 RBNZ PIVOT TO PAYMENTS MODERNISATION WHERE CBDCs ARE A NEW RAIL IN A NEW PAYMENTS SYSTEM

A November 2025 Briefing for the Incoming Governor[3] showed that the RBNZ had:

pivoted to focus on a broader modernisation of New Zealand’s domestic retail payments infrastructure, of which Digital Cash would be a subset (a new rail in a new payments system) if it were decided to be an appropriate investment.

It revealed that the RBNZ would work extensively across different sectors to enable these functions. The OIA response demonstrates that a broader implementation than the original four-stage pathway encompassing ‘legislative, regulatory and governance reform of the payments system’ is occurring.

CONSENT, THIRD PARTY AGREEMENTS & INTEROPERABILITY

Individual consent can meaningfully authorise a defined transaction where there is genuine choice and adequate information. It is much less capable of governing the infrastructure surrounding that transaction. Modern payments can involve banks, payment providers, infrastructure operators, digital wallets, identity and authentication services, fraud systems, cloud providers and other third parties. An individual may agree to the service they can see while having little ability to understand or control the wider network through which their information flows.

This weakens both genuine choice, where access to an important payment system leaves little realistic opportunity to refuse its terms, and meaningful understanding, where individuals cannot reasonably know the downstream transfers, linkages, inferences and reuses that an interoperable system makes possible. The boundary between personal and supposedly non-personal data can also become unclear as information is aggregated, transformed, inferred or potentially re-linked to individuals. Clicking ‘agree’ may therefore authorise a payment without constituting meaningful agreement to the wider informational capabilities of the infrastructure.

Austin, Lisa M., Enough About Me: Why Privacy is About Power, Not Consent (or Harm) (January 1, 2014). Forthcoming in Austin Sarat, ed., A World Without Privacy?: What Can/Should Law Do., Available at SSRN: https://ssrn.com/abstract=2524512
Kobayashi K. (2023) Credit money and payment networks are public goods that must be protected at the utmost https://www.zengin-net.jp/en/announcement/pdf/pfmi_disclosure_e_2023.pdf
Mishra N, Agarwal B, (2026) The emerging framework for non-personal data protection in India: perils, promises, and lessons for the developing world, International Journal of Law and Information Technology, 34:eaaf025, https://doi.org/10.1093/ijlit/eaaf025
Pandey, V. (2026) Governing the Stack: Constitutional Limits on India's Digital Public (March 12, 2026). Available at SSRN: https://ssrn.com/abstract=6595278
Lie D, Austin LM, Sun PYP and Qiu W, ‘Automating Accountability? Privacy Policies, Data Transparency, and the Third Party Problem’, In University of Toronto Law Journal, pp. e20200136, 2021.
Musa SS, Shuaib FS, & Zulhuda S. (2026). Data Sharing Act 2025 and the Constitutional Safeguards on Informational Autonomy in Malaysia. Journal of Information Systems and Digital Technologies, 8(1), 81–95. Retrieved from https://journals.iium.edu.my/kict/index.php/jisdt/article/view/693
Sasi A. (2025) Decoding the Indian data governance model: Relooking at Aadhaar. Social Sciences & Humanities Open, 11:101408, https://doi.org/10.1016/j.ssaho.2025.101408

Interoperability magnifies the problem as consent to a payment should not imply consent to persistent participation in a wider interoperable architecture, linkage with identity or government data, or uses that were not reasonably foreseeable when the transaction occurred. As payments, identity and data-sharing systems become more interconnected, consent risks being asked to carry a governance burden it cannot carry.

This is particularly important where identity or biometric systems are involved. Using a fingerprint stored locally on a device to authorise a payment is materially different from participating in a national identity architecture capable of associating payment activity with a persistent identifier.

The policy objective should therefore be meaningful accountability as well as meaningful consent. Architecture should minimise unnecessary data flows and persistent identifiers, preserve purpose limitation, constrain downstream use and make third-party relationships visible. Protection should, where practicable, be built into the architecture rather than depend upon contractual consent. Payment interoperability need not entail universal informational interoperability.

APRIL 2025 – INDIA’S UPI AS A POSSIBLE MODEL

In an April 2025 communication to the Minister of Finance, Nicola Willis, the RBNZ noted[4]:

The declining support for EFTPOS by industry participants and their increasing dependence on

scheme (Visa and Mastercard) solutions for retail payments creates increasing risk for the resilience and efficiency and cost of New Zealand’s disaggregated payments landscape, which in turn has implications for productivity and economic growth. Modern real-time payments systems are prevalent globally, in both advanced and emerging economies, while New Zealand is now the only OECD country without a modern real-time payments system.

An RBNZ Aide Memoire (April 17 2025) from Assistant Governor Karen Silk to the Minister of Finance points to India's UPI as a possible model. Importantly, UPI is not itself a CBDC. It is a payments infrastructure that carries private bank money, while also providing an acceptance network for India's pilot Digital Rupee CBDC. This is an important distinction. The potential modernisation of New Zealand's payments infrastructure could deliver many of the claimed benefits of faster and cheaper digital payments without requiring the introduction of a retail (e.g. public facing) CBDC. This April 17, Aide Memoire from the Assistant Governor to the Minister of Finance reveals that the RBNZ is actively seeking to work with foreign jurisdictions on the matter of expanding this area.[5]:

We have previously briefed you on our Digital Cash (central bank digital currency) work. The purpose of this paper is to provide an overview of potential synergies between our Digital Cash work and broader payments modernisation, focusing and building on recent engagement with the National Payments Corporation of India (NPCI).

As a part of our Digital Cash work, we are engaging with other government agencies with an operational interest in payments. To date this has been focussed on sharing information about Digital Cash and some of the broader opportunities for efficiency and innovation for their operational and policy needs.

The Aide Memoir explained the UPI functionality:

‘a digital infrastructure that enables real-time payments, allowing instant money transfers between bank accounts using mobile devices. It supports both peer-to-peer (P2P) and person-to-merchant (P2M) transactions, improving efficiency, competition, innovation, and financial inclusion.’ The … ‘UPI connects various products and services, including

instant payments, offline payments, a domestic debit and credit scheme, and welfare payments. The primary acceptance method is QR code-based payments, which are available free of charge to small merchants across India.’

This paper reveals a deliberate intention of the RBNZ to integrate CBDCs into the prospective digital infrastructure, notwithstanding that in July 2025 the Treasury was expressing that there was ‘limited clarity around the associated costs or whether the benefits would ultimately outweigh these costs.’[6]

INDIA IS NOT MERELY A COMPARATOR: UPI IS A PLAUSIBLE PATHWAY FOR NEW ZEALAND

India warrants particular scrutiny because UPI is not merely one of several international examples cited by RBNZ. Reserve Bank documents show that it has been actively investigated as a possible pathway for New Zealand payments modernisation, while the developing bilateral relationship with India provides a separate route towards interoperability between the countries' payment infrastructures.

On 21 March 2025, RBNZ Board Chair Neil Quigley and Bank staff met the National Payments Corporation of India (NPCI) in Mumbai during the Prime Minister's trade delegation. The meeting was initiated by RBNZ following earlier NPCI outreach to Payments NZ through Ministry of Foreign Affairs and Trade (MFAT). The briefing states that during discussions between MFAT and India, NPCI's UPI was identified as ‘an area of mutual benefit in the strengthening bilateral trade relationship between New Zealand and India’. It then describes UPI as ‘widely regarded as the world's leading modern payments system’ and presents it as an affordable alternative to Visa and Mastercard capable of supporting real-time domestic and cross-border payments. [24]

By September 2025, RBNZ had undertaken research into potential uses for ‘a Fast Payment System like India's Universal Payments Infrastructure (UPI)’, to inform its strategic proposal and assessment of options. India and UPI remain within the August 2026 Issues Paper's comparative evidence, while disclosed material indicates further engagement with India. [25] [26]

That pathway became more significant when New Zealand and India signed their Free Trade Agreement on 27 April 2026. The Agreement provides for promoting ‘interoperability and interlinkages of electronic payment infrastructures’ and, more specifically, collaboration towards real-time payment infrastructure supporting domestic interoperability, cross-border remittances and merchant payments, and integration of the countries' Fast Payment Systems.

These developments make India materially different from an ordinary international comparator. There is no disclosed decision that New Zealand will adopt UPI, and the Issues Paper states that future platform and governance choices remain open. However, the documentary record establishes a credible policy pathway: RBNZ initiated direct engagement with NPCI; UPI was identified in bilateral discussions as an area of mutual benefit; RBNZ subsequently incorporated research on a UPI-like fast-payment system into its strategic work; India remains part of RBNZ's international evidence base; and the signed NZ–India FTA now expressly provides for collaboration on real-time payment infrastructure and integration of the countries' fast-payment systems.

India: The Power of the Stack

UPI has delivered extraordinary benefits in speed, cost and scale, while operating through a common national payment rail run by the National Payments Corporation of India (NPCI), with competition among banks and payment applications above it. Yet UPI does not stand alone. It forms part of a much wider digital architecture commonly described as the India Stack, encompassing interoperable capabilities for payments, digital identity, authentication and data exchange.

The significance of the stack lies not simply in its individual components, but in the cumulative capability created when those components can work together. UPI itself does not require Aadhaar for every payment, and the different components should not be collapsed into a single system.

Interoperability can concentrate capability without concentrating formal ownership. Hundreds of banks, applications and service providers may compete at the visible edge, while relying upon common infrastructure beneath it. Similarly, payment, identity and data systems may remain separately administered while common identifiers, authentication and exchange mechanisms increase the capacity to connect information and activity across domains. Power can therefore accumulate through the architecture as a whole without any single institution owning every component.

This is why India should be examined as an institutional and constitutional case, not simply as evidence that real-time payments are technologically feasible. Indian scholarship has raised questions concerning purpose limitation, mandatory linkage, data-sharing safeguards, cross-stack accountability and oversight of the architecture as a whole. The relevant question for New Zealand is not whether UPI is successful. By conventional payment metrics, it plainly is. It is which elements of the wider architecture New Zealand is contemplating adopting, connecting to or reproducing, and what cumulative capabilities those choices create.

That question is particularly important because RBNZ's Issues Paper introduces the World Bank's Digital Public Infrastructure model, describing payments, data sharing and identity/e-signature as ‘separable but interconnected’ building blocks capable of producing ‘multiplier effects’. Yet the consultation does not squarely ask whether some of these infrastructures should remain institutionally or informationally separated, what limits should govern cross-domain identifiers and linkage, or whether some forms of interoperability should deliberately be constrained.

The question is therefore not simply whether UPI provides fast, cheap payments. It is what power the wider stack creates when payments, identity and data infrastructure become interoperable, where that power resides, and what prevents capability in one domain from becoming power across the others.

RBNZ AUGUST-SEPTEMBER 2025 DRAFT PROPOSAL: AGENCIES NOTIFIED OF THE BROADER INFRASTRUCTURE POTENTIAL

A 21-page release (OIA2526-140) explained that the RBNZ’s recent Digital Cash work had concentrated on developing a business case, but that it considered a wider examination of retail payments infrastructure appropriate. Board Paper for Decision 2.3 (August 14, 2025) sought ministerial endorsement for RBNZ to lead development of payments modernisation. The draft paper for the Minister of Finance, can be found on page 10 of that release.

The draft paper noted that the proposal had been shared with the Treasury, MBIE, DIA, Commerce Commission, FMA and Public Service Commission had been consulted, and RBNZ records those agencies as broadly supportive of it taking the strategic leadership role. The paper notes that the RBNZ would have an expanded role in:

‘legislative reform … to formalise mandates and oversight powers across regulators, and to support the delivery and operation of new infrastructure.’ [7]

The September 18 2025 Draft Paper for the Hon Nicola Willis to sign (on page 17/21), showed that officials clearly understood the interconnections between the retail payments landscape, and the potential overlap with ‘core digital public infrastructure’ (commences from page 14/21):

Leveraging industry expertise and government collaboration

22. Modernising the New Zealand retail payments landscape will require a multi disciplinary approach across the public and private sector. A key lesson from overseas jurisdictions is the need for strategic leadership from the public sector and regulators, alongside technical input and delivery from the private sector.

23. In addition, there are strong reasons to coordinate the delivery of core digital public infrastructure – digital ID, open data and modern payments. We know from global experience that delivering these in a coordinated way will strengthen the productivity benefits relative to delivering each in isolation. In New Zealand, good progress is now being made on digital ID and data, but there has been no meaningful progress on upgrading our digital payments infrastructure.

24. We propose to take this work forward on the following basis:

25. RBNZ providing overall leadership on development of a near term strategic proposal for Q1 2026 and a medium term high-level indicative business case for June 2026, working closely with the MBIE, Commerce Commission, FMA, Treasury, Public Service Commission, and Department of Internal Affairs. The nature and timing of the June deliverable can be scaled up or down dependent on government preference,

(a) Industry engagement to bring together banks, fintechs, key players in New Zealand’s digital economy (e.g. 9(2)(a) who we understand has talked to Ministers about a workshop or roundtable to kick this off), and Payments NZ. We envision private sector playing a strong role in delivery and implementation of potential solutions and thus early buy-in is crucial.

The issue has now moved beyond whether New Zealand should introduce a retail CBDC. RBNZ has expanded its focus to modernising the wider payments system, including consideration of a Unified Payments Interface (UPI)-like fast-payment system. The Bank recognises the linkages available from the adoption of digital ID, and has used the rationale that New Zealand risks falling technologically behind, increasing reliance on offshore payment providers and reducing domestic control over critical payments infrastructure to address larger issues of institutional design to move on this.

The concern appears to include what RBNZ describes as potential market failure:

An example of market failure is that the low cost EFTPOS network is likely to REDACTED 9(2)(b)(i), 6(b) leaving New Zealand almost wholly dependent on high-cost international scheme products and ‘rails’ for retail payments.’ [8]

RBNZ CBDC STATEMENTS OF INTENT: HAVE NEW ZEALAND MPs READ THE FINE PRINT?

Under the Reserve Bank of New Zealand Act 2021, Parliament established a statutory framework that removed the previous requirement for the House to ratify Reserve Bank funding agreements (discussed in more detail below).

The RBNZ's retail CBDC project occupies an unusual funding position. Under s 209(5)(b)(viii) of the Reserve Bank of New Zealand Act 2021, the Minister of Finance and RBNZ agreed that expenditure on the CBDC capital project, including preparation of its detailed business case and ‘subsequent costs and expenses’, is exempt from the ordinary limits imposed by the Five-Year Funding Agreement.[9] [10] [11]

The ‘introduction of a Central Bank Digital Currency’ is described by Treasury as a ‘large capital project’. Somewhat remarkably, it is an accounting decision to place the funding of the CBDC programme refurbishment and infrastructure spending outside the ordinary funding envelope:

Costs and expenses incurred by the RBNZ in preparing the detailed business cases and subsequent costs and expenses for the following capital projects: 2 The Terrace refurbishment or replacement; New cash vaulting infrastructure; Central Bank Digital Currency

Unlike specified exemptions for currency production and implementation of the Deposit Takers Act, the CBDC exemption contains no stated monetary ceiling.

The Funding Agreement is required to be presented to Parliament but, under the 2021 Act, is no longer subject to parliamentary ratification. While this mechanism does not itself authorise the issuance of a retail CBDC, it permits potentially substantial expenditure on developing the project outside the ordinary funding limits before Parliament has made any decision on whether New Zealand should issue a retail CBDC.

Therefore, the particular decision to exempt CBDC business-case and subsequent project expenditure from the ordinary funding limits was not expressly authorised by a parliamentary vote.

Members of Parliament no longer have approval or veto rights over the expenditure limits established through the RBNZ Five-Year Funding Agreement. The agreement is negotiated between the RBNZ and the Minister of Finance and progressed through executive and Cabinet processes. Once signed, it takes effect without parliamentary ratification and is subsequently presented to the House rather than submitted to it for approval.

Importantly, the Minister is required to present a copy of a funding agreement or a variation of a funding agreement to the House of Representatives within 12 sitting days after the agreement or variation is entered into.[12] Members of Parliament have no approval or veto rights.

In parliamentary practice, however, presentation does not require the Minister to address the House, explain the document, initiate debate or seek a vote. A Minister may present a paper simply by delivering it through the Clerk of the House. Its presentation is then recorded in the Journals and the document made available to MPs.

CBDC-RELATED WORK PROGRAMME TREATED AS 'EXCLUDED CAPITAL EXPENDITURE'

The RBNZ Statement of intent 2024-2028 and Statements of Performance Expectations (2025/2026 and 2026/27) were the only reports that could be identified from a search in the Publications Library for ‘digital cash’ or ‘CBDC’ from October 2024-August 2026.[13] [14] [15]

The Statements of Performance Expectations (2025/2026 page 25; 2026/27 page 24) reveal how the RBNZ's CBDC budgets were folded into a larger 'capital project'. One line in each of these statements reveals that the funding for the RBNZs CBDC strategy has been expressly excluded and classified as ‘excluded expenditure’. It is in fine print:

Due to the font being small we have reproduced the text:

Expenses incurred by the RBNZ which are excluded from the funding agreement include:

(b) The following expenditure agreed by the Minister of Finance and the Bank to be exempt expenditure under section 209(5)

(vii) Costs and expenses incurred by the Bank to prepare detailed business cases and subsequent costs and expenses for the following capital projects; 2 The Terrace refurbishment or replacement, new cash vaulting infrastructure, and Central Bank Digital Currency; [16] [17]

The RBNZ's 2026/27 Statement of Performance Expectations document records the excluded expenditure outside its ordinary Five-Year Funding Agreement at $49 million in 2025/26, increasing to $74 million in expenditure in 2026/27. These sums cover several activities and cannot exclusively be attributed to CBDC development.

The exemption covers not only preparation of a detailed CBDC business case, but also ‘subsequent costs and expenses’ associated with the CBDC capital project. Unlike some other exempt expenditure categories, the agreement specifies no monetary ceiling for CBDC expenditure.

PSGRNZ cannot see a monetary ceiling attached specifically to CBDC expenditure in the agreement and we have been unable to identify any budgetary estimates.

However, if CBDC expenditure has expressly been exempted from the ordinary funding limits, and the quoted sums are vague with respect to how the CBDC/digital cash campaign, which includes work undertaken for the wider work programme – the question arises: If Parliament has not authorised a retail CBDC, what precisely is the statutory and appropriation/accountability pathway by which RBNZ can incur those ‘subsequent costs and expenses’?

STATEMENT OF INTENT 2024-2028

The RBNZ's Statement of intent 2024-2028 discusses the Future of Money work programme. The Digital Cash project is recognised as an element of a larger work programme. [18]

Digital Cash: we are exploring introducing a digital form of central bank money as another form of central bank money, alongside cash. Digital cash is exploring the risks and opportunities as a consequence of the increasing digitalisation of money. (page 20)

The direct effect is that members of Parliament do not need to read the agreement and evaluate its meaning. The Funding Agreement needs only to be lodged on the parliamentary website under:

Home > Parliamentary > Business > Papers Presented> Current Papers[19]

Parliament's Papers Presented record shows that the Reserve Bank of New Zealand, Te Pūtea Matua, 2025–2030 Five-Year Funding Agreement, RBNZ Forecast Operating and Capital Expenditure Budgets[20], April 2025, published date April 29, 2025, sits on the parliamentary page. It contains only three pages of text.

Presentation made the agreement formally available to members; it did not require parliamentary debate or approval

As of August 2026, The RBNZ statement of performance expectations for 2026/27 had not been presented to the House (though previous statements have been). The bank’s performance expectations, if presented, would likely be examined by select committee as part of the financial scrutiny cycle.

2021 LEGISLATIVE CHANGES LED TO REDUCED PARLIAMENTARY SCRUTINY IN 2025

The first five-year Funding Agreement made wholly under the new regime expressly excluded CBDC business-case and subsequent project expenditure from its ordinary expenditure limits.

The RBNZ’s Funding Agreement with the Minister of Finance, and the Statement of Performance Expectations 2026/27 lodges the cost of CBDCs alongside office refurbishment and new cash vaulting infrastructure (without clarifying the extent of budget set aside for CBDCs); and the Statement of Intent (2024-2028) states that New Zealand is investigating them, moving later in the document to exclusively refer to CBDCs as ‘digital cash’ without providing clear explanation.

The first new five-year Funding Agreement operating entirely under the 2021 Act's regime in which parliamentary ratification was no longer required, was also the first Funding Agreement expressly to create a capital-project expenditure exemption which would include any budgeted funding of CBDCs.

There has been a material reduction in direct parliamentary control over the RBNZ Funding Agreement. The statutory Funding Agreements are five-year agreements. The 2025–30 agreement is especially important because it is the first full five-year agreement under the 2021 Act and, from the material we have found, the first one to expressly name Central Bank Digital Currency as a capital project whose detailed business-case and subsequent expenditure can sit outside the ordinary funding limits.

The previous legislation required Parliament to approve RBNZ's five-year Funding Agreement by resolution before it could take effect. The Reserve Bank of New Zealand Act 2021 removed this requirement. Under the new regime, the Funding Agreement is agreed between the Minister of Finance and the RBNZ and subsequently presented to the House, but MPs are no longer required to vote to approve it. It is not known what rationale was given around 2020–21 for replacing parliamentary ratification with the new Minister–RBNZ funding mechanism?

Treasury's Regulatory Impact Assessment: A New Institutional Framework for the Reserve Bank[21] argued that greater flexibility was required as the funding agreement could be amended at any time. Although the existing legislation allowed a funding agreement to be amended at any time by agreement between the Minister and the RBNZ, amendments had been rare. Treasury considered that the requirement for the funding agreement, and any amendment, to be ratified by Parliament reduced flexibility and may have discouraged amendments. Treasury also criticised the existing funding process as lacking transparency, because it provided insufficient detail to stakeholders about how funding levels were determined and how funds would be allocated across the RBNZ's functions.

The reforms therefore sought greater transparency through more detailed budgets, publication and reporting. However, this was accompanied by the removal of a different and important form of transparency and accountability: formal parliamentary ratification. Rather than requiring elected representatives to approve the five-year Funding Agreement by resolution before it could take effect, the new framework required the agreement and supporting budget to be tabled in Parliament. Treasury considered parliamentary ratification ‘unnecessary’, arguing that tabling, Annual Reviews and other reporting mechanisms would provide sufficient parliamentary oversight.

Publication and tabling can increase the amount of information technically available to MPs and the public, while simultaneously reducing Parliament's decision-making authority. Under the former regime, MPs were required to vote to ratify the Funding Agreement.

Under the new regime, the agreement can be formally ‘presented to the House’ through the parliamentary papers process. In practice, the parliamentary papers process is the lodgement on the parliamentary website, without elected representatives being required to read the RBNZ Funding Agreement and understand its import, or to debate or approve it. Thus, a reform intended to improve flexibility and informational transparency also shifted an element of financial control away from Parliament and towards the Minister and the RBNZ.

RBNZ AUGUST 2026 ANALYSIS & ISSUES PAPER - IS STRIKINGLY LIMITED

The Issues paper (August 2026) outlines that the work programme encompasses the ownership and operation of future payment infrastructure, strategic leadership, regulatory powers, access, governance, interoperability and the degree of centralisation or decentralisation across the system.

It calls for a ‘system-wide, future-focused view’, but applies this principally to technological capability, interoperability, integration and adaptability. A genuinely system-wide perspective must also consider the institutional architecture through which power over critical payment infrastructure will be exercised. Coherence and coordination do not require institutional concentration. Common infrastructure can coexist with dispersed ownership, independent governance, central-bank settlement, regulatory oversight and competition at other layers.

The future-facing question is therefore not simply whether New Zealand's payment infrastructure can accommodate the next technology, but whether its governance will protect resilience, contestability, national autonomy and democratic accountability for decades to come. Parliament could, for example, establish a Digital Public Infrastructure Act defining the purposes, limits and safeguards for DPI, allocating statutory responsibilities and carefully bounding regulatory and rule-making powers.

Yet the consultation does not clearly put the fundamental question before the public:

How much infrastructural, informational and institutional power should any single institution or common architecture be permitted to acquire? Which functions should remain separate as a constitutional or public-interest safeguard, even where integration might produce greater efficiency?

These are long-lived institutional choices. A central bank can provide final settlement without owning or operating the retail payment rail. Infrastructure can be operated by banks, mutually owned utilities, private entities, public-private bodies or central banks. Competition between payment services can coexist with highly concentrated infrastructure beneath them. Equally, separately governed infrastructures can interoperate without being consolidated.

International experience illustrates this diversity. Japan combines industry-owned infrastructure with central-bank settlement; Korea combines common industry infrastructure with central-bank participation and separate settlement; Switzerland concentrates one layer while dispersing ownership and governance; and Norway combines common bank infrastructure with central-bank settlement while retaining alternative payment channels and contingency capacity. Institutional differentiation can strengthen an integrated system rather than weaken it.

Yet the consultation identifies efficiency, resilience, competition, innovation and interoperability as objectives without clearly presenting the materially different institutional arrangements through which they might be achieved. Respondents are asked who should lead, govern and operate future infrastructure, but are given few concrete comparative models. The public is largely left to invent alternatives rather than assess established ones.

More fundamentally, material disclosed to date does not demonstrate that RBNZ has systematically reviewed the international legal, constitutional or public-law literature on digital public infrastructure, interoperable payments, digital identity, informational concentration and institutional power. These are highly important, relevant considerations - the Issues Paper itself contemplates centralisation and decentralisation and introduces the World Bank's Digital Public Infrastructure framework, without directly examining the safeguards and limits those choices may require.

Modern payment systems unquestionably require central-bank expertise. But technical expertise should not expand into authority over fundamentally political questions: who controls critical national infrastructure; how institutional power is distributed; how much informational integration citizens should accept; which independent alternatives should survive; and what dependencies New Zealand should accept. The central bank should inform these choices, not inherit them.

Nor should institutional resourcing be mistaken for institutional suitability. RBNZ has substantial autonomy over its operational resources, while expenditure attributable specifically to its payments-modernisation leadership has not been separately identified in information disclosed to date. Other agencies, and the Council of Financial Regulators (CoFR) as a coordinating body, do not appear to have equivalent independent capacity to resource a major payments-modernisation programme.

The 2025 parliamentary banking inquiry identified governance problems concerning both RBNZ and the bank-owned Payments New Zealand, including accountability, infrastructure control and independent oversight. Yet its recommendation to progress real-time payments was not accompanied by substantive consideration of who should own, control or govern the resulting critical national infrastructure. Criticism of Payments New Zealand should have prompted deeper consideration of long-term infrastructure stewardship, not an assumption that greater central-bank direction solves the governance problem. MBIEs current role as regulator is largely technical, and broader questions of public law and governance have largely not been addressed.

Australia illustrates why conflicts are important to address. Its New Payments Platform was developed as industry-owned common infrastructure, while the Reserve Bank of Australia separately provided real-time final settlement. The Australian Productivity Commission subsequently identified competition risks associated with access to the New Payments Platform, warning of the need for a formal access regime before incumbency became entrenched. Australia demonstrates both that central-bank settlement does not require central-bank ownership of the retail rail, and that keeping infrastructure outside the central bank does not itself guarantee competition or plurality.

These concerns later resurfaced when the Australian Competition and Consumer Commission (ACCC) scrutinised the 2021 consolidation of NPP Australia, BPAY and eftpos under Australian Payments Plus, initially raising concerns about reduced infrastructure competition and frustrated third-party access to the NPP, and ultimately requiring a court-enforceable undertaking before authorising the merger.

These issues are directly relevant to institutional separation and the wider constitutional principle that significant public powers should not be unnecessarily concentrated.

A SOLUTION? COMPETITION AT THE RETAIL LAYER & INSTITUTIONAL SEPARATION AT THE INFRASTRUCTURE LAYER

Digital public infrastructure is not merely technical infrastructure. Its design allocates power: who may participate, who establishes identity, who can observe transactions, how information can be connected across systems, and who controls essential channels of economic participation. These are questions of constitutional as well as technical design.

Institutional separation should not automatically be treated as inefficiency or fragmentation. In critical national infrastructure, separation can limit concentrations of power, preserve independent alternatives, reduce common-mode failure, constrain informational aggregation and retain future democratic choices.

The same distinction matters for resilience. Plurality at the retail-payment or communications layer is not fragmentation of final settlement. International systems combine common settlement, plural payment channels, interoperable rails and independent infrastructure in different ways. The question is not whether centralisation is good or bad, but what genuinely needs to be centralised and what should remain separate or contestable.

PAYMENTS WITHIN THE WIDER DIGITAL ARCHITECTURE: THE FUTURE INTEROPERABILITY POTENTIAL

Payments modernisation will not exist in isolation. The Issues Paper expressly introduces the World Bank concept of Digital Public Infrastructure, describing payments, data sharing, identity and e-signature as ‘separable but interconnected’ building blocks whose combination can produce ‘multiplier effects’. It maps New Zealand's Consumer Data Right, open banking and digital-identity framework onto this broader architecture.

But payment interoperability, identity interoperability and government-data interoperability are different policy choices. Real-time payments do not require a universal government identifier, biometric identity architecture or persistent linkage between banking and administrative databases. Yet as these infrastructures become increasingly interoperable, the informational capabilities of public and private institutions can expand substantially.

The Issues Paper discusses the efficiencies and benefits of interconnected DPI without an equivalent examination of persistent identifiers, biometric authentication, cross-domain linkability, informational concentration, purpose creep, citizen visibility or accumulated institutional power.

This is why the governance question cannot simply be who is capable of delivering modernisation. It is how the powers created by modernisation should be distributed, bounded and independently overseen.

CoFR, Institutional Separation and the Asserted Strategic Leadership Gap

The Issues Paper identifies a ‘strategic leadership gap’ as a central weakness in New Zealand's retail payment system. Yet the Council of Financial Regulators (CoFR) already provides a mechanism through which agencies with different statutory responsibilities can coordinate while retaining their respective mandates. A failure of coordination does not necessarily establish a failure of institutional separation, or the need for stronger leadership by a single regulator.

CoFR articulated a Payments Vision in 2023, but subsequent work, according to the Issues Paper, ‘largely focused on other priorities within individual agencies rather than a coordinated long-term strategy’. The Paper also acknowledges that CoFR's new operating model, including targeted taskforces, could provide a vehicle for the cross-agency governance required for payments modernisation.

It is therefore unclear whether limited progress reflected an inherent deficiency in the CoFR model, or more practical constraints such as funding, staffing, ministerial direction or agency priorities. Nor is it clear whether strengthening or specifically resourcing CoFR, including through a dedicated payments taskforce, was considered as an alternative to stronger RBNZ leadership.

As the RBNZ must appreciate, institutional separation can itself serve a public purpose. Prudential and settlement responsibilities, competition regulation, market conduct and wider government policy involve different statutory objectives and expertise. The Issues Paper recognises this principle in New Zealand's separation of conduct and prudential regulation, but does not appear to examine whether stronger coordination between institutionally separate regulators could address the payments problem without concentrating strategic direction within the institution responsible for central-bank settlement and financial stability.

THREE WAYS POWER CAN BECOME CONCENTRATED

The policy questions raised by real-time payments extend beyond speed or interoperability. They concern three distinct forms of infrastructural concentration.

Institutional concentration: who owns and operates essential infrastructure; who sets rules and access; where settlement and strategic leadership reside; and whether genuinely independent alternatives remain.
Informational concentration: what information becomes visible; whether persistent identifiers enable previously separate records to be connected; and whether payment, identity and government data can be linked, creating new institutional capabilities.
Biometric and identity concentration: whether authentication remains local to a device or financial institution, or becomes part of reusable national identity infrastructure spanning payments and government services. A device fingerprint is fundamentally different from a national biometric identity capable of authenticating the same person across banking, taxation, health or welfare. Between these lie bank biometrics, national identity systems, payment-linked national identifiers and cross-domain authentication infrastructure.

These dimensions can move independently. Institutional decentralisation does not guarantee informational decentralisation. A privately or mutually owned payment rail may rely on highly centralised identity infrastructure; conversely, final settlement may be concentrated at a central bank while retail infrastructure, identity and service provision remain institutionally separate.

International comparison should therefore go beyond labels such as ‘central-bank-led’, ‘government-led’ or ‘industry-led’. It should identify where concentration actually occurs, and what legal, technical and governance boundaries prevent concentration in one layer from becoming power across others.

REFERENCES

[1] Pandey, V. (2026) Governing the Stack: Constitutional Limits on India's Digital Public (March 12, 2026). Available at SSRN: https://ssrn.com/abstract=6595278 Page 14

[2] RBNZ Briefing for the Incoming Governor, November 2025.

[3] RBNZ (June 4, 2026). Response to OIA2526_186. Information about the Governor’s Induction. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/oias/2026/june-2026/oia2526_186-response.pdf

[4] RBNZ (April 17, 2025). Aide Memoire: Payments Infrastructure and Digital Cash. #6279. To Hon Nicola Willis. From Karen Silk Assistant Governor. Page 2. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/information-releases/2026/payments-infrastructure-and-digital-cash-6279.pdf

[5] RBNZ (April 17, 2025). Aide Memoire: Payments Infrastructure and Digital Cash. #6279. To Hon Nicola Willis. From Karen Silk Assistant Governor. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/information-releases/2026/payments-infrastructure-and-digital-cash-6279.pdf

[6] The Treasury (July 22, 2025). Meeting with the Reserve Bank of New Zealand Board T2025/1755 CM-1-3-122-8-4-M120497 https://www.treasury.govt.nz/sites/default/files/2026-02/rbnz25-review-5185337.pdf

[7] RBNZ (February 11, 2026). Response to OIA2526_140: Information about CBDC (Central Bank Digital Currency) and Digital Payments. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/oias/2026/mar-2026/oia2526_140--central-bank-digital-currency-and-digital-payments.pdf

[8] RBNZ (February 11, 2026). Response to OIA2526_140: Information about CBDC (Central Bank Digital Currency) and Digital Payments. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/oias/2026/mar-2026/oia2526_140--central-bank-digital-currency-and-digital-payments.pdf

[9] The Treasury (April 2025). EXP-25-SUB-0037 Reserve Bank of New Zealand Five-Year Funding Agreement 2025-30. https://www.treasury.govt.nz/sites/default/files/2025-04/cabinet-paper-exp-25-sub-0037-rbnz-five-year-funding-agreement-2025-30.pdf

[10] The Treasury (September 2025) Reserve Bank of New Zealand 2025-30 Funding Agreement . https://www.treasury.govt.nz/sites/default/files/2025-09/t2025-190-5068512.pdf

[11] RBNZ (April 9, 2025). Funding Agreement Between The Minister of Finance and The Reserve Bank of New Zealand https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/funding-agreements/2025-30-funding-agreement.pdf

[12] Reserve Bank of New Zealand Act 2021. https://legislation.govt.nz/act/public/2021/31/en/latest/

[13] RBNZ (Undated) Reserve Bank of New Zealand Statement of Intent 2024-2028. ISSN 1177-9144 (online). https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/statements-of-intent/statement-of-intent-2024---2028.pdf

[14] RBNZ (Undated) Reserve Bank of New Zealand Statement of Performance Expectations 2025/26. ISSN 2815-8679 (Online) Page 25. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/statement-of-performance-expectations/statement-of-performance-expectations-2025-to-2026.pdf

[15] RBNZ (Undated) Reserve Bank of New Zealand Statement of Performance Expectations 2026/27. ISSN 2815-8679 (Online). https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/statement-of-performance-expectations/statement-of-performance-expectations-2026-to-2027.pdf

[16] RBNZ (Undated) Reserve Bank of New Zealand Statement of Performance Expectations 2025/26. ISSN 2815-8679 (Online) Page 25. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/statement-of-performance-expectations/statement-of-performance-expectations-2025-to-2026.pdf

[17] RBNZ (Undated) Reserve Bank of New Zealand Statement of Performance Expectations 2026/27. ISSN 2815-8679 (Online). https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/statement-of-performance-expectations/statement-of-performance-expectations-2026-to-2027.pdf

[18] RBNZ (Undated) Reserve Bank of New Zealand Statement of Performance Expectations 2026/27. ISSN 2815-8679 (Online) Pages 20-21. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/statement-of-performance-expectations/statement-of-performance-expectations-2026-to-2027.pdf

[19] https://bills.parliament.nz/papers?Tab=Current

[20] New Zealand Parliament (April 29, 2025). Reserve Bank of New Zealand, Te Pūtea Matua, 2025–2030 Five-Year Funding Agreement, RBNZ Forecast Operating and Capital Expenditure Budgets. https://bills.parliament.nz/v/4/3e548f72-4a8e-49df-258d-08dd8142cef9?lang=en

[21] The Treasury. Regulatory Impact Assessment: A New Institutional Framework for the Reserve Bank, originally December 2019 and updated March 2020 https://www.treasury.govt.nz/sites/default/files/2020-07/ria-tsy-rbnz-jul20.pdf

[22] OIA request response 2526_140. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/oias/2026/mar-2026/oia2526_140--central-bank-digital-currency-and-digital-payments.pdf

[23] RBNZ (Sept 9 2025) In Confidence Paper. The Reserve Bank’s role in Payments Modernisation. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/information-releases/2025/briefing-to-minister-payments-modernisation.pdf

[24] RBNZ (April 17, 2025) Aide Memoire #6279. To Hon Nicola Willis, from Karen Silk. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/information-releases/2026/payments-infrastructure-and-digital-cash-6279.pdf. Released 2026

[25] RBNZ (Sept 9 2025) In Confidence Paper. The Reserve Bank’s role in Payments Modernisation. Ref # 6304 https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/information-releases/2025/briefing-to-minister-payments-modernisation.pdf

[26] OIA request response 2526_140. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/oias/2026/mar-2026/oia2526_140--central-bank-digital-currency-and-digital-payments.pdf

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