Submissions

Age Concern New Zealand welcomed the opportunity to submit feedback on the Ministry of Social Development’s Long-Term Insights Briefing.

We believe that New Zealand is unprepared for an ageing population.

We suggest that that top three priority topics are: home ownership, savings, and access to service.

The top three limitations to live well are: loss of housing, relationship breakdown, separation or divorce, and development of a long term health condition or disability.

The top three focus areas of the Long-Term Insights Briefing are: income support (including NZ Superannuation), social housing, and supporting communities.

Other long-term issues to consider are ethnic disparities, health, and the broader picture. 

Age Concern New Zealand welcomed the opportunity to submit comments on the proposed changes to Web Standards.

We are encouraged by the commitment to accessibility for all publicly funded New Zealand government digital content and services so that they are usable by people with disabilities.

Overall, Age Concern New Zealand supports the proposed changes to Web Standards.

Age Concern New Zealand welcomed the opportunity to submit comments on the Draft Strategy to Prevent and Minimise Gambling Harm 2025/26 to 2027/28.

Overall, we see the Draft Strategy as a positive step forward, our comments and recommendations are primarily to do with older New Zealanders and problem gambling harm.

Age Concern New Zealand welcomed the opportunity to submit feedback on the Medical Aspects of Fitness to Drive consultation

We acknowledge the important role that driving plays in the lives of many New Zealanders, allowing them to lead independent lives and stay connected with people, services, places & activities. 

Age Concern New Zealand welcomed the opportunity to submit feedback on the Vocational Education and Training Reforms consultation.

We acknowledge the important role that the vocational education system plays in the training of many New Zealanders equipping them to work in trades, healthcare, information technology, food & fibre sectors and community care 

Age Concern New Zealand welcomed the opportunity to submit feedback on the inquiry into the aged care sector’s current and future capacity to provide support services for people experiencing neurological cognitive disorders

Age Concern New Zealand strongly supports the development and resourcing of services for people with neurological cognitive disorders across the care continuum from home and community care to residential care and palliative care 

Age Concern New Zealand welcomed the opportunity to submit feedback on the consultation ‘Making it easier to build granny flats’

We support making it easier to build self-contained high quality small units providing the check and balances in the Building Act and Resource Management Act apply as outlined in the discussion document.

Age Concern New Zealand welcomed the opportunity to comment on the Residential Tenancies Amendment Bill.

Homeownership has been declining since the 1980s. In 2022, the Retirement Commission estimated that by 2048, 40% of people 65 and over will be renting, equating to up to 600,000 people. This will be a 100% increase from 2018. Therefore, Age Concern New Zealand call for the recognition that renting and home ownership must be viable at all life stage, including older age.

Key comments:

• We strongly oppose allowing landlords to terminate a tenancy with a ‘no-cause eviction’ due to the significant health and social risk to tenants, including older tenants
• Similarly, we believe a landlord should be required to provide a reason if they do not want a fixed-term tenancy to continue as a periodic tenancy
• We do not support reducing notice periods from 63 to 42 days for termination with a reason
• We support the intention to allow more pets in rentals
• We support the additional situation in which a tenant may withdraw from a tenancy due to family violence
• We oppose retroactively applying the legislation to existing tenancies

Age Concern New Zealand welcomed the opportunity to submit feedback on the recommendations from New Zealand’s fourth Universal Periodic Review.

We strongly support the recommendation to ensure older people are adequately represented in the inter-ministerial human rights mechanisms.

Age Concern New Zealand welcomed the opportunity to submit comments on the Fire and Emergency Levy 2026-2029 consultation.

After reviewing the consultation document it is our view that the preferred levy increase will disproportionately impact older New Zealanders 

Age Concern New Zealand welcomed the opportunity to submit comments on the draft Commission 111 Contact Amended Code 2023.

Overall, Age Concern New Zealand supports the majority of the proposed amendments to the Code. 

Age Concern New Zealand does not support the proposed amendment in Clause 37 that if a consumer moves premise, but remains with their provider, the provider may check the consumer’s status and potentially require them to re-apply if something material has changed.

Recommendations:

1. Develop a national awareness campaign

2.  Section E Requirement on providers to inform all consumers about options available for vulnerable consumers: Clause 7.4. We recommend that information about where consumers can refer a dispute or complaint under the Code is also required to be highly visible and in accessible formats on relevant websites

3. Section E Requirement on providers to inform all consumers about options available for vulnerable consumers: Clauses 6.6 and 31. We recommend that the Commission consider the impact of some older people lacking confidence using technology in determining what is an appropriate alternative means of accessing 111.

4. Section J Requirement on providers to disclose information. We recommend the Commission considers requiring providers to also disclose the length of time it takes for each application to be processed from the date it is received.

Age Concern New Zealand welcomed the opportunity to submit feedback to Toka Tū Ake EQC on the Natural Hazards Insurance Act dispute resolution scheme.

The dispute resolution process appears sound to us. There is a clear pathway and clear regular communication is required with all parties throughout the process. We are pleased to see an appeal process through the courts is available if any of the parties involved are unhappy with the adjudicator’s decision. We agree with a timeframe of 90 days after the date the dispute is referred to the mediation process being built into the process. Lengthy processes with no defined end point place unreasonable additional pressure on homeowners.

One of the challenges will be how homeowners get to hear about the dispute resolution scheme and whether they have the confidence and resources to take a dispute to the scheme provider. The cost involved may be a deterrent despite the Commission being responsible for the costs of administering the Scheme itself. We are interested to know how low fixed income homeowners, including those living solely on New Zealand Superannuation, will be assisted to engage with the disputes process. The cost for legal representation would be prohibitive for many superannuitants and other low fixed income New Zealanders.

We are pleased that homeowners can take a support person with them to mediation and any meetings with the mediator, adjudicator or the Commission. This will be especially important for some older people, people with disabilities and those for whom English is a second language. Having a support person will help many homeowners to deal with a process that is unfamiliar and formal