Submissions

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 

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.

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

Age Concern New Zealand welcomed the opportunity to submit feedback on the Financial Markets Authority’s draft Fair Outcomes for Consumers and Markets: A guide to outcomes-focused regulation

Overall, Age Concern New Zealand supports the proposed outcomes and approach. We believe the outcomes identified are reasonable and would meet the expectations of consumers. Access to, and engagement with, financial services is an important part of older people’s wellbeing and ageing well in their communities.

We emphasise the importance of accessible information and communication with consumers. The issue we see is more with how effective implementation of the Code will be measured or assessed. Training and a monitoring framework of some form will be needed to ensure the Code lives up to its aim and intent.

We believe the success of the framework will be shaped by the approach of the Financial Markets Authority in their work with providers to meet the outcomes. The intent of establishing fair outcomes for consumers and markets is commendable, but implementation comes down to multiple providers interacting with a wide range of people, who may be under pressure at the time.

We would like to see a process developed for consumer and consumer advocate groups to share their experiences with the Financial Markets Authority after the regulations have been implemented and providers have started taking steps to meet the outcomes.

Age Concern New Zealand supports the development of a Code of Insured Persons’ Rights to outline the standard of service insured people can expect from Toka Tū Ake EQC. The management and settlement of claims after a natural hazard event, such as an earthquake or landslide, is important to any insured homeowner. There is also potential for an insured person to face the distressing impact of multiple natural hazard events. This is challenging for anyone, especially for many older New Zealanders and people with disabilities. 

Older New Zealanders are a diverse, resilient and valued part of every community. Some of the older adults in our communities will need greater support and help when making an insurance claim after a natural hazard event. Older people are not all the same, any more than any other population group. However, older people that are frail, have a disability or live alone may require extra support throughout the process. Older adults may not use digital technology as regularly as others, or at all, which is a disadvantage at a time where much information and many forms that need completing are online. We urge those developing the Code and Insurers working with older homeowners ensure ageism does not impact on their interactions with older people.The issue we see is more with how effective implementation of the Code will be measured or assessed. The intent is laudable and pleasing to see, but implementation comes down to multiple home insurance providers interacting with a wide range of people, who will likely be under considerable stress at the time. Training and a monitoring framework of some form will be needed to ensure the Code lives up to its aim and intent.

Age Concern New Zealand supports updating the legislation to protect the interests of current and future residents and to enable retirement villages to operate under a legal framework readily understandable to residents and operators.

We acknowledge the importance of retirement villages as a housing option for older New Zealanders, with just over 50,000 now living in retirement villages. Age Concern New Zealand and member organisations strongly recommend that the Ministry for Housing and Urban Development prioritises the key areas in any final decisions and we provide our recommendations.

Age Concern New Zealand supports updating legislation to guide our preparation, response, and recovery from emergency events. Aotearoa has been experiencing severe weather events which are extremely challenging for people living in affected communities, as well as for the organisations responsible for responding to those events.

Older New Zealanders are a diverse, resilient, and valued part of every community. Some of the older adults in our communities will need greater support and help in an emergency, others will be amongst the helpers. Older people who are frail, have a disability or live alone may require extra help in an emergency. Some may not have whānau or friends living nearby, or they may need help to evacuate their home or get to higher ground. If injured, they are likely to take longer to recover. Older adults may not use digital technology as regularly as others, or at all. Displacement and disruption resulting from emergency events make it difficult for older adults to access healthcare, obtain medication, receive home support or have access to equipment they require.

Our submission provides recommended actions.