Submission Sunday: Public Service Amendment Bill
I know, it's no longer Sunday but here we are
This is another one of those terribly boringly titled Bills that have some nasty hooks in them once you start reading it.
Ostensibly, the Bill amends the Public Service Act 2020 to drive improvements in public service performance, create more stability, and ensure that the public service efficiently and effectively delivers value for money.
In reality, it strips out and weakens the public service commitment to equity, inclusion, and participation, introduces a very narrowly defined notion of “efficiency”, and inserts greater powers for senior managers to contract out work. Contractors are not bound by the same requirements as employees. In short, this Bill:
Removes explicit references to diversity and inclusion
Side-lines a range of marginalised groups, including disabled people and families.
Focuses on a narrow definition of “efficiency” while simultaneously undermining specialist supports
Delegates more responsibility to contractors while reducing accountability for accessibility and disability rights.
You can find the Bill and submission portal here. Submissions close 31 August.
I’ve summarised the issues with the Bill into themes - again, feel free to shamelessly plagiarise as you like, or use it as a basis for your own ideas and responses. It is tedious, tiresome work, writing submission, and the more resources you have to make it easier, the better I say!
Equity, Inclusion, and Participation
The Public Service Amendment Bill 2025 proposes removing explicit references to diversity, equity, and inclusion from the Public Service Act 2020, asserting that these obligations are covered by other legislation. While these principles still exist in laws such as the Human Rights Act and Equal Pay Act, their removal from the central Act risks reducing the visibility and prioritisation of disability issues across agencies[i].
Disabled people and their families face reduced assurance that accessibility, reasonable accommodations, and inclusive practice will be embedded across public services. The narrowed purpose statement focuses on supporting government policy, delivering efficient services, meeting New Zealanders’ needs, and acting lawfully, while removing references to “active citizenship” and the “long-term public interest.” This shift moves towards marginalising disabled communities in decision-making processes, reduces the commitment to co-design, and narrows opportunities for meaningful participation[ii].
Efficiency, Performance, and Delegation
The Bill emphasises value for money and efficiency, which, while important, could disproportionately affect specialist or tailored supports relied on by disabled people and families. Services that are complex, person-centred, or resource-intensive – notably, disability supports, communications, and accessibility – become harder to justify under a narrow efficiency framework[iii]. The Bill also expands delegation powers for chief executives, allowing them to assign responsibilities to contractors’ employees. Increased reliance on contracted providers leads to inconsistent service provision and patchy quality. It also weakens direct accountability for accessibility and disability rights obligations, making it harder for families to ensure safe, equitable, and responsive public services[iv].
Accountability, Leadership, and Digital Accessibility
The Bill introduces mechanisms for annual misconduct reporting and regular long-term insights briefings, which could improve transparency in service delivery, including disability-related services. However, these briefings are controlled by central government, meaning disabled voices may not be centred, included or even prioritised in determining topics or outcomes. Strengthened leadership roles across finance, digital, and HR functions have potential to improve consistency across agencies, but without explicit mandates for accessibility and universal design, digital exclusion and workplace barriers may persist[v]. Mandatory accessibility standards are critical to ensure vision-impaired users can access online services and information fully[vi].
Emergency Planning and Inclusion
Amendments to civil defence and business continuity provisions could enhance protections for disabled people during emergencies, a group historically at greater risk[vii]. However, without explicit reference to disability-inclusive emergency planning, disabled people and their families could once again be overlooked during crises[viii]. Ensuring that emergency planning is inclusive, and that disabled communities have input into priorities, is essential to safeguard their rights and well-being.
The Bill and the UNCRPD
Relevant UNCRPD articles:
Article 3: Principles of participation, inclusion, equality – Establishes the fundamental principles guiding all CRPD implementation, ensuring that disabled people are treated equally, included in society, and actively participate in decisions affecting their lives.
Article 4: Obligations of States to protect and promote rights – Requires States to adopt legislation, policies, and measures to guarantee the human rights of disabled people and to eliminate discrimination in all areas of life.
Article 19: Living independently and being included in the community – Affirms the right of disabled people to live independently, choose their place of residence, and access community services and support to fully participate in society.
Article 29: Participation in political and public life – Ensures disabled people can take part in political and public activities, including voting, holding office, and engaging in civic decision-making on an equal basis with others.
Article 31: Statistics and data collection for monitoring rights – Obligates States to collect accurate data and statistics on disabled people to monitor the implementation of rights and inform evidence-based policies and programs.
The proposed Bill upholds aspects of transparency and accountability (annual reporting on misconduct, long-term insights briefings) and could support better monitoring and data-informed policy (Article 31).
The proposed Bill does not uphold Articles 3, 29. The removal of explicit equity, diversity, and inclusion commitments weakens the public service’s obligation to actively promote non-discrimination and participation, including against people with disabilities.
The proposed Bill does not uphold Articles 3, 19. The narrowed purpose statement and efficiency focus works to undermine citizen participation and co-design of services.
The proposed Bill does not uphold Articles 4, 19. Delegation to contractors without explicit accountability for accessibility and disability reduces effective rights protection.
The Bill and the NZ Disability Strategy:
The Strategy’s vision is for New Zealand to be a non-disabling society. Key goals include upholding disabled people’s human rights, participation in society, and achieving positive outcomes. The refreshed strategy includes employment as a key outcome, with a goal of providing employment opportunities for disabled people.
The proposed Bill upholds strengthened leadership structures and reporting mechanisms could indirectly support better oversight of service delivery.
The proposed Bill does not uphold equity and inclusion, weaking public services and removing accountability for actively embedding the Strategy (including the refreshed strategy). Efficiency-driven mandates place pressure services to cut or streamline supports, meaning that participation and quality outcomes for disabled people are often the first to go. The extremely limited references to engagement with disabled people risk failing the emphasis on co-design and user voice.
The Bill and Enabling Good Lives Principles:
Relevant EGL Principles:
Self-determination: Disabled people make choices about their lives.
Person-centred approaches: Tailored supports, not “one-size-fits-all.”
Easy to use: Disabled people have supports that are simple to use and flexible.
Relationship building: Supports build and strengthen relationships between disabled people, their whānau and community.
The Bill’s reporting and insight mechanisms could provide opportunities for data to inform better, person-centred services.
The Bill does not uphold / risks undermining self-determination: Efficiency and cost-focused framing may conflict with choice and tailored supports, undermining self-determination. Delegation to contractors without clear inclusion standards weakens person-centred delivery. Narrowed public service purpose and removal of inclusion references reduces opportunities for co-design and engagement necessary for designing services that are easy to use and relationship building practice.
By failing to integrate these frameworks, the Bill risks reversing decades of progress toward inclusive, responsive governance. Embedding the NZ Disability Strategy and EGL principles into the Bill is essential to honour New Zealand’s legal and ethical obligations toward disabled people.
[i] Albom, S., & Grayman, J. H. (2025). A Comparative Analysis of Disability Policies in Aotearoa New Zealand and the United Kingdom Through the Lens of the Capability Approach. Journal of Human Development and Capabilities, 26(3), 1–20. Retrieved from https://www.tandfonline.com/doi/full/10.1080/19452829.2025.2502023
[ii] Human Rights Commission. (2023). Report finds disabled people among those who experience persistent disadvantage. Retrieved from https://www.whaikaha.govt.nz/news/news/report-finds-disabled-people-among-those-who-experience-persistent-disadvantage
[iii] MacNeill, P. J. (2023). Employment opportunities for disabled people in the New Zealand disability sector. Retrieved from https://mro.massey.ac.nz/bitstreams/a5e84480-e122-45f6-88a4-cf528816dadd/download
[iv] Smith, M., Blamires, J., & Click, M. F. (2022). The Impact of Policies and Legislation on the Structure and Delivery of Support Services for Children with Cerebral Palsy and Their Families in Aotearoa New Zealand. Nursing Praxis in New Zealand, 38(1), 1–10. Retrieved from https://www.nursingpraxis.org/article/38925-the-impact-of-policies-and-legislation-on-the-structure-and-delivery-of-support-services-for-children-with-cerebral-palsy-and-their-families-in-aotearoa
[v] New Zealand Government Digital Services. (2025). Accessibility and GenAI. Retrieved from https://www.digital.govt.nz/standards-and-guidance/technology-and-architecture/artificial-intelligence/responsible-ai-guidance-for-the-public-service-genai/customer-experience/accessibility
[vi] Blind Low Vision NZ Accessibility Guidelines. Retrieved from https://blindlowvision.org.nz/resources/accessibility-guidelines/
[vii] Civil Defence Emergency Management. (2013). Including People with Disabilities. Retrieved from https://www.civildefence.govt.nz/assets/Uploads/documents/publications/guidelines/information-series/13/13-disabilities/is-13-13-including-people-with-disabilities.pdf
[viii] Bay of Plenty Civil Defence Emergency Management Group. (2015). Disaster Preparedness for People with Disabilities. Retrieved from https://www.bopcivildefence.govt.nz/media/1168/disaster-preparedness-for-people-with-disabilities.pdf
Thanks for your mahi on this. We have now started a “submissions and snacks” group — called WTAF — so will definitely use this info 🙏
Brilliant. And shared.
Thank you. Thank you. We must not let the bastards grind us down.
This autocratic Government is creating autocratic legislation that will strip human rights, and we must educate the public to use their voice, their words or borrow words they agree with, to stand against this onslaught.
They only win when we let them win.