Regulatory AlertsNew Zealand: fintech & payments regulation
Partially regulatedNo VASP regime; FMI Act 2021 governs payment systems; AML/CFT Act 2009 applies to transfers
- Lead regulator
- Reserve Bank of New Zealand
- Also involved
- Financial Markets Authority (securities) · FIU (AML reporting)
- Core law
- AML/CFT Act 2009 · Financial Market Infrastructures Act 2021
- Entry capital
- —
- Approval timeline
- —
- Customer assets
- No specific protection; unregulated
- Data protection
- Privacy Act 2020 · Office of the Privacy Commissioner
- Sandbox
- —
New Zealand has no specific licensing regime for VASPs or e-money issuers; these activities are unregulated under financial services law. However, the Reserve Bank of New Zealand (RBNZ) strictly oversees payment systems under the Financial Market Infrastructures Act 2021. All money transfer and remittance businesses must register as Reporting Entities under the AML/CFT Act 2009 and comply with strict wire transfer regulations.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | Unregulated No specific payment processing licence; AML/CFT registration required | — | — | — |
| E-money & wallet issuance | Unregulated No e-money licence; no specific regulatory framework | — | — | — |
| Domestic money transfer | RegistrationReporting Entity[1] Must register under AML/CFT Act 2009 | — | — | Reserve Bank of New Zealand |
| Cross-border remittance | RegistrationReporting Entity[1] Must register under AML/CFT Act 2009 | — | — | Reserve Bank of New Zealand |
| Agent network | Uncertainverify with regulator Agent network rules unclear | — | — | — |
| Open banking / account information | Uncertainverify with regulator Open banking framework unclear | — | — | — |
| Foreign-exchange services | Unregulated No FX licence; AML/CFT registration required | — | — | — |
New — what changed recently
- 2024-06-01Wire Transfer Regulations 2024 — Enhanced originator and beneficiary data requirements for international wire transfers under the AML/CFT Act.[1]
- 2024-03-01Financial Market Infrastructures Act 2021 Designation — Designation of NZCDC and other systems as designated financial market infrastructures under the FMI Act.[2]
- 2023-07-06Deposit Takers Act 2023 — Royal Assent received for the Deposit Takers Act, establishing a new prudential regime for deposit takers.[3]
Market-entry checklist
- 1Register as Reporting EntityRegister with the Reserve Bank of New Zealand under the AML/CFT Act 2009 if handling money transfers.
- 2Implement AML/CFT ProgrammeEstablish a comprehensive anti-money laundering and counter-financing of terrorism programme.
- 3Comply with Wire Transfer RulesEnsure originator and beneficiary data compliance for international transfers under the 2024 regulations.
- 4Assess FMI StatusDetermine if your payment system qualifies as a designated Financial Market Infrastructure under the FMI Act 2021.