August 2025
Tirohanga Whānui | Overview
The New Zealand Council of Christian Social Services (NZCCSS) welcomes the opportunity to provide feedback on the amendments to the Public Service Act 2020. We challenge the kaupapa to roll back provisions and progress on diversity and equity in our public service. The public service endures beyond individual government terms, and changes to the operation and purpose of the public service have long-term impacts on our country.
Our main points are:
- We recommend retaining the following purposes of the public service in legislation:
- supporting the Government to pursue the long-term public interest
- supporting the Government to facilitate active citizenship
- We recommend retaining provisions for pay equity and combating bias and discrimination
- We recommend the Public Service Amendment Bill not be pursued further at this stage given the findings of the Regulatory Impact Statement.
Kōrerorero | Discussion
Item One – We recommend retaining support for the Government to pursue the long-term public interest as a public service purpose
The public service’s fundamental characteristic is acting with a ‘spirit of service’ to the community (Scott, 2023). Combined with its enduring nature, the apolitical foundation of the public service relies on its ability to transition between governments with the goal of long-term public interest. We support the update to the responsibilities of a chief executive to include “providing advice on the long-term implications of policies” and recommend this intention be carried through the bill by maintaining the purpose for the public service to support government to pursue the long-term public interest.
Item Two – We recommend retaining support for the Government to facilitate active citizenship as a public service purpose
Enshrining the concept of active citizenship into the Public Service Act 2020 reinforced a commitment to ensuring that democracy in New Zealand was to be protected and supported by the public service (Te Kawa Mataaho, 2023). The notion that a citizen was entitled to be an active member of the political process, through voting, through writing submissions and consultations, through petitioning, and through being answerable to by the Government via Official Information Act requests, is critical to ensuring that our democratic rights as citizens are protected. Removal of this requirement works to reduce trust in the public service and the Government that they serve.
Item Three – We recommend retaining the requirement for consideration to be given to pay equity and diversity and inclusiveness
The public service has been at the forefront of pay equity in Aotearoa, with the Government Service Equal Pay Act 1960 predating the much wider Equal Pay Act 1972 by over a decade (Te Kāwanatanga o Aotearoa). The removal of pay equity from public service workforce policy and employment policies is a backward step.
Appointment on merit, similarly, is a concern when used as a dog-whistle designed to roll back diversity and inclusion guidelines. The removal of consideration for diversity and inclusiveness undermines the breadth of factors that may contribute to an appointment being best fit for a role. The recognition of diversity and inclusiveness also encourages a public service that reflects the people they serve. Minister Collins herself has been noted as having “not seen any examples of people who had been hired into the public service for diversity rather than merit reasons” (Daalder, 2025), and the feedback from the consultation noted that multiple departments and ministries disagreed with the removal of Diversity, Equity and Inclusion supports from the legislation (Te Kawa Mataahao, 2025).
Item Four – We recommend this Bill not be pursued further at this stage given the findings of the Regulatory Impact Statement
The Regulatory Impact Statement (RIS) for the Public Service Amendment Bill clearly outlines that there has been insufficient time to analyse the Public Service Act 2020 due to its recency. It also notes that there has been limits on consultation and analysis of this amendment before presentation due to a constrained policy development timeline, and the RIS did not indicate what level and which groups were consulted in the development of this amendment. It further notes that there was an inability to determine if these changes would produce greater benefits than costs. We therefore recommend this Bill not progress any further.
Ngā Tohutoro | References
Daalder, M. (2025). Collins to strip diversity, pay equity rules from public service law. Newsroom.
https://newsroom.co.nz/2025/08/01/collins-to-strip-diversity-pay-equity-rules-from-public-service-law/
Scott, R. J. (2023). A Spirit of Service to the Community: the fundamental characteristic of the public service. ISBN 978-0-473-70187-1. https://www.publicservice.govt.nz/assets/DirectoryFile/A-spirit-of-service-to-the-community.pdf
Te Kāwanatanga o Aotearoa | New Zealand Government. Pay equity in Aotearoa New Zealand:
History/Context and Principles. https://www.publicservice.govt.nz/assets/DirectoryFile/Pay_Equity_Context_and_Principles.pdf
Te Kawa Mataaho |Public Service Commission (2023). Active Citizenship – ways to have your say.
https://www.publicservice.govt.nz/news/active-citizenship-ways-to-have-your-say
Te Kawa Mataaho | Public Service Commission (2025) Public Service Act amendments – updated draft Cabinet papers (MoSR 2025-0228, 14 March, 2025)
Ingoa whakapā | Contact Name
Alicia Sudden [email protected]
Rachel Mackay