Tirohanga Whānui | Overview
The New Zealand Council of Christian Social Services (NZCCSS) welcomes the opportunity to provide feedback on the Social Security (Jobseeker Support and Accommodation Supplement) Amendment Bill. We challenge the kaupapa to restrict eligibility for Jobseeker Support and the Accommodation Supplement. The proposed changes are likely to create increased financial hardship among groups of people who are already experiencing financial pressure. Increased focus on education and training is recommended to address youth not in employment, education or training (NEET) rates.
Our main points are:
Jobseeker Support
- The Bill will increase financial pressures on whānau
- Youth unemployment rates indicate challenges in securing work
- Provision of Working for Families (WFF) for those impacted by this policy change
- Concern for impacts on whānau and rangatahi Māori
- Concern for impacts on disabled young people and their whānau
- Potential for the Parental Support Gap test to increase vulnerability and hardship among
young people
Accommodation Supplement
- Concern for increased financial pressure on households
- Concern for impacts on whānau Māori
- Support for exclusion of older people from this policy
Taunakitanga | Recommendations
We raise the following points and recommendations for consideration:
Part One. Tightening eligibility criteria for Jobseeker Support
Item One: The Bill will increase financial pressures on whānau and rangatahi
NZCCSS believes this Bill will lead to increased financial hardship among whānau who become
financially responsible for young people unable to access work, and young people who are unable to rely on their parent(s) for financial support. We are concerned about the impact this may have on
already stretched household budgets, particularly on top of increases in the cost of living in recent
years and the current impacts of the fuel crisis. As noted in the Regulatory Impact Statement (RIS)
these changes may result in increased demand for our members’ services, such as food parcels, which have already seen significant increases in demand (Salvation Army, 2026). Recent research indicates an increase in people seeking welfare support for the first time, and that among both those receiving welfare support and those working, people are struggling to cover living costs (CAB, 2026). We are also concerned about the potential for these changes to negatively affect family relationships due to increased financial stress.
Recommendation 1: We recommend that this Bill does not proceed.
Item Two: Youth unemployment rates indicate challenges in securing work
We support alternative approaches to reducing youth NEET rates, such as Option 2 in the Regulatory Impact Statement which recommends Government provides more education and training services for young people, including addressing numeracy and literacy barriers to employment, education and training. Youth have been significantly impacted by unemployment in the current economic context, with the NEET rate rising to 13.6% among 15-24 year olds in the year to March 2026 (MBIE, 2026). The Salvation Army (2026) State of the Nation report identifies that the number of NEETs was higher in the year to September 2025 than it has been in 20 years, increasing by almost 16,000 young people in the past two years. We are concerned that, as noted in the RIS, young people who are unable to access Jobseeker Support will find themselves also without the training and work search support that is part of the benefit provision. Recent research highlights the challenges young jobseekers experience, including facing numerous rejections or silence from employers, and difficulties in accessing effective training and support (IDEA, 2025). Additionally, the RIS identifies that lack of educational qualifications and driver’s licences are the primary barriers to employment for young people. This legislation will increase the challenges youth face in a difficult employment market. To strengthen employment supports available to young people, we refer to the recommendations in The Pipeline of Potential (IDEA, 2025) including reviewing the active labour market policies focused on youth, providing longer term funding to NGOs, trialling community commissioning of youth employment supports and exploring a Circuit-Breaker Job Guarantee initiative.
Recommendation 2: We recommend that Option 2 of the RIS is pursued as an alternative strategy to reducing youth NEET rates, alongside strengthening of employment supports available to young
people.
Item Three: Provision of Working for Families (WFF)
Working for Families is currently paid to families of children aged 18 and under. The proposed changes will mean that families of young people who are ineligible for Jobseeker will also be without Working for Families entitlements for that young person once they turn 19. This will leave families worse-off financially without the additional support WFF provides.
Recommendation 3: We recommend that Working for Families be extended up to 20 years where
there is a dependent NEET young person.
Item Four: Concern for impacts on whānau and rangatahi Māori
Article 3 of Te Tiriti o Waitangi upholds the right to equity for Māori. We are concerned that this
legislation may have a disproportionate impact on both Māori and Pacific young people and their
whānau due to their overrepresentation in the benefit system and NEET rates (MBIE, 2019; MSD,
2025). The proposed legislation may increase financial hardship among these young people who
already experience higher rates of material hardship than other groups. Research indicates that
greater investment in culturally appropriate employment and training services, designed and
delivered by Māori and Pacific providersis needed (IDEA, 2025). Research also suggests that initiatives focused on increasing school engagement and access to driver’s licenses are likely to be the most effective in addressing inequities in NEET rates among Māori and Pacific young people (MBIE, 2019).
Recommendation 4: We recommend this Bill does not proceed and that there is increased investment in education support, culturally appropriate employment support services and improved driver’s license access for young people.
Item Five: Concern for impacts on disabled young people and their whānau
We do not support inclusion of Jobseeker – Health Condition, Injury or Disability in this policy change. Child poverty statistics show that disabled children and their families are at increased risk of
experiencing financial hardship and as noted in the RIS, have higher costs of living. We are concerned that the parental income limit does not recognise differing costs for different family situations, nor the different costs that may be associated with seeking work among different groups of young people. We believe this change removes a significant safety net for those with health conditions and disabilities and conflicts with the purposes of the Social Security Act 2018 which includes the provision of financial and other support to help people for whom work is not currently appropriate due to sickness, injury, disability or caring responsibilities.
Recommendation 5: We recommend that Jobseeker – Health Condition, Injury or Disability be
excluded from this policy
Item Six. Potential for the Parental Support Gap test to increase vulnerability and hardship among young people
NZCCSS supports inclusion within the legislation of young people who have been in care, and those
who have had a caregiver receiving the Unsupported Child’s Benefit, within those meeting the
Parental Support Gap criteria. We are concerned that the Parental Support Gap criteria will further
isolate young people who cannot rely on their family for financial support, but who are unable to
satisfy MSD’s criteria. This includes young people for whom reliance on their parents may create
significant distress due to past abuse or trauma. This policy change may exacerbate hardship among
young people, who have also faced restrictions in recent years in accessing supports such as
emergency housing and who remain without adequate housing and financial assistance (Hendry,
2025). Given that this test involves case worker discretion, there is potential for it to be applied
inconsistently and for some young people to be disadvantaged. Further detail on the criteria for this
test is needed to understand the implications for young people.
Recommendation 6: We recommend the scope of the Parental Support Gap test be expanded beyond the two specific situations noted in the legislation, to support fairness and consistency in its
application.
Part Two. Changes to Accommodation Supplement
Item One. Concern for increased financial pressure on households
The proposed change to the Accommodation Supplement entry threshold will increase financial
pressure among low-to-middle income beneficiary and working households. Our members report
increasing financial hardship within community, with greater demand for services such as food and
housing support. The loss of around $40 per week in Accommodation Supplement, as estimated in the Supplementary Analysis Report (SAR), is likely to increase hardship and need. In addition to the
impacts of this policy on housing affordability and security, including potential declines in home
ownership rates, the potential impacts on child material hardship rates are concerning, given that
almost 70% of the households likely to be affected include children. The potential for some impacted by this change to also lose access to a Community Services Card is another by-product of this policy that may have negative flow on effects regarding family healthcare access. We note the likelihood of this policy impacting disproportionately on specific groups, such as sole parents who are studying and the impact, while not disproportionate, on Pacific families who experience lower rates of home ownership.
Recommendation 1: We recommend that these changes do not proceed due to the likelihood of
increased financial hardship.
Item Two. Concern for impacts on whānau Māori
As noted above, Article 3 of Te Tiriti o Waitangi upholds the right to equity for Māori. The SAR identifies that this change is likely to have a disproportionate impact on Māori, including the potential to impact Māori home ownership rates. The SAR also notes that consultation with Māori has not been possible.
Recommendation 2: We recommend targeted consultation with Māori regarding the proposed
changes, including how any negative impacts could be better mitigated if the legislation proceeds.
Item Three. Support for exclusion of older people from this policy
We support the proposed exclusion of specific groups, such as those receiving Superannuation, from this policy and appreciate the acknowledgement that older people, and those receiving the Supported Living Payment may be unable to sustain any further increases in accommodation costs.
Recommendation 3: We recommend that, as proposed in this Bill, people receiving New Zealand
Superannuation (NZS), Veteran’s Pension (VP), Supported Living Payment (SLP) and Emergency Benefit (EB) are not included in this policy.
Ngā Tohutoro | References
Citizens Advice Bureau. (2026). Mana Āki – Dignity for All.
www.cab.org.nz/assets/Documents/About-us/Social-Policy/Spotlight-Reports/2025-CAB-Welfare-Report-Final.pdf
Hendry, A. (2025). Our kids sleeping on the streets. https://e-tangata.co.nz/comment-and-analysis/our-kids-sleeping-on-the-streets/
Institute for Democratic and Economic Analysis (IDEA). (2025). The Pipeline of Potential: How New
Zealand can better connect businesses with untapped local talent.
static1.squarespace.com/static/65f78d3721113065243d2312/t/68830005645ed3149b06dcd
a/1753415698853/IDEA_INSTITUTE_REPORT_.pdf
Ministry for Business, Innovation & Employment. (2026). Youth not in employment, education or
training in New Zealand. webrear.mbie.govt.nz/theme/neetrate/map/timeseries/2026/new-zealand?right-transform=absolute
Ministry for Business, Innovation & Employment. (2019). The drivers behind the higher NEET rate for
Māori and Pacific youth. www.mbie.govt.nz/dmsdocument/10353-the-drivers-behind-thehigher-neet-rate-for-maori-and-pac
Ministry of Social Development. (2026). Supplementary Analysis Report: Increasing the entry
threshold for the Accommodation Supplement for some homeowners. www.msd.govt.nz/documents/about-msd-and-our-work/publications-resources/regulatoryimpact-statements/sar-increasing-the-as-entry-threshold-for-homeowners.pdf
Ministry of Social Development. (2025). Regulatory Impact Statement: Tightening access to
Jobseeker Support and Emergency Benefit for 18 and 19 year olds. www.msd.govt.nz/documents/about-msd-and-our-work/publications-resources/information-releases/cabinet-papers/2025/tightening-access-to-jobseeker-support-and-emergency-benefit-for-18-and-19-year-olds/regulatory-impact-statement-tightening-eligibility-for-18-and-19-year-olds.pdf
New Zealand Government. (2018). Social Security Act.
www.legislation.govt.nz/act/public/2018/32/en/latest/#DLM6783121
The Salvation Army. (2026). State of the Nation 2026. www.salvationarmy.org.nz/sppu/wpcontent/uploads/sites/31/2026/02/TSA_SOTN26_FullReport_ONLINE2.pdf
Ingoa whakapā | Contact Name
Alicia Sudden ceo@nzccss.org.nz
Melanie Wilson
