New Zealand businesses are operating in one of the most demanding regulatory environments in recent years, with 2025 marked by significant regulatory reform, rising compliance expectations, and more assertive enforcement priorities across key sectors.

Regulators are placing greater emphasis on proactive compliance, transparency, and clear systems for managing obligations, making it increasingly important for organisations to move beyond ad hoc approaches to compliance.

In this context, maintaining a structured and up to date Obligations Register is becoming a practical expectation of good governance and effective regulatory engagement.

This alert outlines the recent developments shaping these expectations and discusses how organisations can strengthen their compliance frameworks.

Regulatory expectations are rising

2025 marked a material shift in New Zealand’s regulatory landscape. Across agencies, the common themes are stronger stewardship expectations, more active monitoring, and a firmer enforcement posture.

A major year of regulatory reform

New Zealand’s regulatory settings are undergoing their most significant recalibration in years. The Regulatory Standards Act 2025 [1] and the establishment of the Ministry for Regulation have introduced new expectations for how regulation is designed, implemented, and reviewed. Agencies are now required to demonstrate clearer accountability for regulatory performance, while regulated entities face greater scrutiny over whether their governance and compliance systems are fit for purpose.

The OECD Regulatory Policy Outlook 2025 [1] highlights strengthened regulatory stewardship capabilities, expanded monitoring, and systematic data collection and review across regulatory systems, reinforcing expectations for evidence based regulatory management.

A tougher enforcement stance

The regulatory mood has also become more assertive in the past year. For example, the Commerce Commission’s 2025/26 Enforcement Priorities [3] signal an increased willingness to take action where conduct risks consumer harm, undermines competition, or breaches sector specific rules. The Commission has emphasised:

• earlier intervention, including targeted inquiries and greater use of information gathering powers;

• greater reliance on penalties and public enforcement outcomes to drive deterrence; and

• heightened expectations for internal systems, with regulators looking beyond breaches to the quality and robustness of organisational controls.

This more interventionist approach is echoed across other regulators, many of whom are now actively testing whether organisations can demonstrate an auditable line of sight from regulatory obligations through to internal policies, controls, assurance processes, and reporting. For example: 

• the Ministry for Regulation’s stewardship framework emphasises ongoing system monitoring and accountability; 

• the Financial Market Authority’s outcomes focused supervision stresses the need for strong internal systems and controls [4]; the Reserve Bank’s enforcement criteria place greater weight on responsiveness, system efficacy, and governance capability [5], and 

• sector specific regulators such as Taumata Arowai have also intensified monitoring, focusing on whether regulated suppliers can demonstrate effective, functioning systems for managing legal obligations in practice [6].

Increased expectations for proactive compliance

Across the regulatory system, the shift is toward proactive - not reactive - compliance. Regulators expect organisations to:

• anticipate regulatory change rather than simply respond to it; 

• maintain auditable systems that show real time or reliable, traceable monitoring of obligations; and

• demonstrate that senior leadership and boards are actively overseeing compliance risks.

Organisations relying on informal or decentralised compliance practices are finding it harder to satisfy regulator expectations, increasing the likelihood of remediation demands, investigation costs, and governance scrutiny.

Conversely, entities with structured obligations management systems are better positioned to avoid regulatory surprises and engage constructively with regulators.

Why an Obligations Register matters now

While New Zealand law does not expressly require a formal “obligations register”, directors’ duties, sector specific requirements, and the regulatory emphasis on stewardship increasingly mean organisations must be able to show:

• what their obligations are;

• how they are monitored;

• how compliance is maintained; and

• how changes are tracked over time.

A centralised obligations register provides:

• clear visibility of applicable legal and regulatory obligations;

• accountable governance frameworks that support directors and senior leaders;

• audit trails that demonstrate compliance proactively;

• efficiency, by replacing inconsistent or ad hoc tracking practices; and

• resilience, by reducing the risk of missed changes or evolving requirements.

In a climate where regulators are focusing more heavily on enforcement, system quality and regulatory stewardship, organisations without a robust obligations management system are increasingly exposed.

How we can help

MinterEllisonRuddWatts’ Obligations Register Service is designed to help New Zealand businesses meet escalating regulatory expectations with confidence..

Our service provides:

• Plain English summaries of the laws and obligations relevant to your business;

• monthly updates, combining automated monitoring with expert legal review to ensure you remain current amid regulatory change;

• secure, cloud based access for easy oversight and governance visibility; and

• customisation, aligned to your industry, licences, consents, approvals, and risk profile.

Whether you operate in a highly regulated sector, manage complex reporting or licensing obligations, or simply want to strengthen your compliance systems, our service provides a structured, defensible approach to regulatory management.

Footnotes

[1] Regulatory Standards Act 2025 No 68, Public Act – New Zealand Legislation
[2] New Zealand: OECD Regulatory Policy Outlook 2025 | OECD
[3] 2025 Enforcement and compliance priority areas
[4] 2025 Financial Conduct Report
[5] Enforcement - Reserve Bank of New Zealand - Te Pūtea Matua
[6] Compliance Monitoring and Enforcement Strategy 2025