Submissions
Ngā Tāpaetanga
2025
ECE Amendment Regulations
We support the Government’s intent to strengthen the regulatory framework by ensuring enforcement is proportionate, transparent, and firmly focused on safeguarding the health, safety, and wellbeing of tamariki.
Our submission emphasises the need to strike a balance between maintaining strong regulatory oversight so the kaiako, whānau and the general public have confidence that our early learning services provide safe, nurturing, teacher-led early learning.
ECE Reform Bill
Licensing Criteria
2024
Removing the NELP from legislation
We disagree with the proposal to remove the statement of NELP from the Act. The NELP provide strategic direction for early learning services, schools, kura, and tertiary. The Government has the opportunity to deliver their education policies utilising the NELP. The NELP is enduring and, when listening to Minister Stanford at recent education forums, she is keen to develop an enduring education system. The NELP can certainly provide the Minister the ability to do so, and she can still be innovative to provide great outcomes for our children, young people and adults education and learning in Aotearoa New Zealand.
ECE Regulatory Review
We submitted on a number of areas of the current regulations including what is working well, what needs minor changes and what needs major changes. We also mentioned areas of duplication between agencies such as ERO as well as areas of inconsistency (both within the MoE and with other agencies).
Funding Determinations and Fee Regulation Settings for 2025
Revoking Network Approval
While we agree that Network Approval added regulatory burden and direct costs to providers, we still believe that there needs to be a mechanism that ensures that whānau have choice of services, including different philosophies and cultures, while enabling the market to respond to the needs of parents and communities.
Revoking the National Statement on the Network of Licensed Early Childhood Services
While we agree with revoking the National Statement as it is overly burdensome, we believe the strategic priorities still have merit.
2023
Education and Training Act Amendment No 3
We agree that the Ministry of Education should be able to access ECE data from Statistics NZ to develop a new Equity Index that is based on accurate socio-economic information. We are satisfied that any data accessed will not include personal information unless the individual has consented to the publication or disclosure.
We strongly agree that employers need to assess police vets for non-teaching employees and contractors. It is crucial that all people working with or having unsupervised access to tamariki at ECE services and schools are not only police vetted but that the results of that vet is assessed for any risks to the safety of children is made.
Amendments to ECE Regulations to accommodate Crown acquisition of land and network approval
We believe this is a sensible change that will make it easier for ECE centres that find themselves in the position of needing to relocate due to no fault of their own.
Adding conditions to provisional licences, defining ‘permanently ceased to operate’ and providing for temporary closures
We support the proposed change to the regulations that will allow the Ministry to respond appropriately and in a timely manner if additional compliance issues are identified. We also agree that where a provisional licence is near the end of the 12 month period and new conditions are found that the Secretary can wait until the current provisional licence period ends and then issue a new provisional licence.
We agree that there is a need for temporary service closures and that the regulations should be amended to formalise the definition of and process of voluntary temporary closures. This will remove any impression that these types of closures are occurring outside the legislation.
Providing a definition of ‘locally based’ for PR in home-based
We agree that the regulations are amended to include a definition of ‘locally-based’ for persons responsible for licensed home-based education and care services. This will remove the current ambiguity for providers, especially those with homes in more rural / remote locations.
2022
Gazetting Te Whāriki
We agree that ECE services and certificated play groups should be required to implements the goals and learning outcomes of Te Whāriki. Gazzetting Te Whāriki would creat clear expectations that every child experiences a rich and empowering curriculum and would support formative assessment. Services will need guidance and exemplars as well as clear expectations from ERO in what they are looking for in terms of evidence of meeting curriculum requirements.
As a bicultural organisation, we agree with including a te ao Māori interpretation of the goals and learning outcomes.
Network Management: Priorities of National and Regional Statements and new regulations
We agree with the proposed priorities and are pleased to see Pacific cultural services as well as bilingual services and immersion services included. We note that services with specific philosophies are not on the priority list. In terms of the regulation, we are happy with what has been proposed.
Fair Pay Agreements Bill
While we are generally in support of Fair Pay Agreements which have the potential to raise and standardise the employment conditions across industries or occupations, we have a number of queries and concerns regarding the proposed Bill and its impact on the Early Childhood Education (ECE) sector.
Supplementary Order Paper to Education and Training Amendment Bill No 2
The SOP introduces the new Network management functions that were consulted on in November 2021
2025
Relief Teacher Pathways
Relief teachers are an important and essential part of our teaching workforce, enabling permanently employed kaiako to take leave and engage in PLD. Relief teaching is a valid option for many qualified kaiako at different stages of their career and keeps them in the profession. Any opportunities to remove barriers, while maintaining professional standards, is welcome.
Nationally Consistent Induction Model
ITE is only the beginning of a teacher’s journey and newly qualified teachers need ongoing supported learning in their setting in the early years of their teaching career. For all new teachers to have access to consistent, high-quality induction and mentoring is crucial to their development and success.
Teaching Standards
The current teaching Standards were first developed in 2017, so a review is timely. The current Standards are far from broken, so we are pleased these were used as a starting point, rather than taking a blank slate approach. The Teaching Council is an independent professional body, and our professional code and standards are titled ‘Our Code, Our Standards’. There is a sense that the revised Standards have been drafted to align with direction of the current Government rather than what the continued expectations are of teachers. The current Standards allow curriculum changes or revisions, growing research, and focus. The core fundamentals of teaching do not change, so the Standards should not be arbitrarily changed as government policies or priorities do. It is important that teachers ‘own’ the Standards - by the profession and for the profession – and that these are not swayed by the government of the day. Professional teaching standards should endure.
2024
Police Vetting Bill
In general, we agree with the changes in the Bill and believe they will streamline the process of vetting staff and where needed volunteers. Our member services are required to police vet all staff under the Childrens Act. Some vets are carried out by the Teaching Council as part of their teacher registration and certification, and for non-qualified staff, vet them using the police vetting service. ECE services also vet volunteers who provide support to their staff. In the past have been issues with the time taken to process a vet which has led to delays in employing staff. The removal of the Education Urgent service a few years ago compounded this situation.
Proposed ITE Changes
In terms of this proposal there is no clear value proposition or problem definition to explain what this proposal seeks to address. As such, it is hard to agree that moving core initial teacher education (ITE) functions from the Teaching Council to the Ministry of Education is the appropriate solution.
Proposed maths entry requirements
While we agree that mathematical competence is a critical aspect of primary teaching, we do not agree that changing the entry requirements for primary ITE is the appropriate lever to achieve this. Primary teachers | kaiako are generalists who must be competent in the whole New Zealand Curriculum, the eight learning areas of English, the arts, health and physical education, learning languages, mathematics and statistics, science, social sciences, and technology.
Primary ITE Requirements
We believe that the proposed changes raise some interesting points, particularly regarding adding more documentation and requirements to what we already have and could be seen to be duplicating what is already in place. We have a set of standards for the teaching profession, in relation to the proposed changes the Design for Learning and Teaching standards fit well - if these were vigorously unpacked, assessed and attested to, it would ensure that students completing an ITE programme would have the skills and knowledge to meet the learning requirements of their tamarki.
Fee for Review of Complaints Assessment Committee
We agree there that the Teaching Council should charge a fee for the review of a CAC decision. There is a significant cost for Teaching Council to review a decision even if by conducting a review on the papers rather than holding another hearing.
Language competency for teaching in Aotearoa
We are extremely pleased that the Teaching Council is focused on developing pathways to support Pacific bilingual and immersion in teaching and learning. We strongly agree that the Teaching Council should develop an indigenous Pacific language competency pathway that has different expectations for English language competence. We also agree that removing the Council’s current English language competency requirement will help reduce barriers for speakers of Pacific languages.
Teaching Council Strategic Plan
We agree that the new vision needs to capture both the work of the Teaching Council, and the role of teachers and teaching.” Strengthening the mana of teaching, so teachers can change lives” is a simple, strong statement. In addition we support all five proposed strategic priorities.
2023
ITE Programme Approval, moderation and review requirements (29 September 2023)
We believe that the current model which is already a high-trust model is working well. We understand the desire to simplify and consolidate, but have concerns about the proposed multi-tier approach.
Pay Parity Funding Review (23 May 2023)
While we agree that there is a benefit of pay parity in the ECE sector we disagree with the approach that the Ministry is proposing. We are extremely disappointed that the Ministry is creating yet another band-aid rather than undertaking a first principles review of early learning funding that we (and others in the sector) have been requesting for several years.
The model proposed provides no incentive for services to operate above minimum teacher:child ratios, operate for more than 6 hours per day or cater to children aged under 2 years of age, creating barriers of choice for whānau and tamariki in accessing ECE
We note that the funding under review does not include Equity Funding or Targeted Funding for Disadvantage. We ask if this will lead to both complication in how this funding is claimed and additional work for services in making multiple funding claims under different systems. Has the Ministry considered impacts on ELI systems, and the potential costs that may flow to providers from this.
Conduct and Competency Process (14 April 2023)
Our submission is on a number of proposed Rules and Rule changes.
2022
Strategic Plan Refresh (3 June 2022)
We commend the Teaching Council on the work completed to date including the new requirements for ITE programmes and the streamlined registration process including moving online. We submit that there is more to do around the pathways for enrolment in initial teacher education and registration for speakers of Pacific languages.
We agree that kaiako need to be more actively engaged and committed in their professional organisation. This has recently come to the fore in teachers’ lack of understanding of what the Teaching Council does for them when the consultation on Fees and Levies was carried out earlier this year.
Fees and Levies (1 April 2022)
We value the work of the Teaching Council in upholding professional teaching standards and we understand its financial need after a decade of no increases or additional Government funding. We commend the Teaching Council on providing comprehensive information on what they are mandated to do in their expanded remit as well as the reasons for the increase in fees and the levy. As a membership organisation of ECE services and kaiako, we’re hearing genuine concern from members whose budgets are stretched to the limit.
2025
NZQA iQAF
NZQA Fee Consultation - Round 2
NZQA Fee Consultation
2024
Future of Work-based learning
No rationale has been given to disestablish the Workforce Development Councils (WDCs). There is no problem defined, so it’s unclear what the change, which will create significant upheaval and cost, is seeking to address.
NZQA’s draft integrated quality assurance framework
We welcome this review of NZQA’s quality assurance framework. Robust quality assurance is imperative to lift and maintain the reputation of New Zealand’s education system, giving our qualifications credibility nationally and internationally. The ideal outcome would be a high-trust model that gives NZQA the necessary trust and confidence in our processes and quality, while reducing the burden of compliance on TEOs.
Changes to the NZ Qualifications and Credentials Framework (NZQCF) and NZQA rules
Overall, we are supportive of the proposed changes to the NZQCF and rules, which strengthen and maintain the integrity of the NZQCF. We have framed our response around the consultation questions.
2022
Changes to NZQA Rules October 2022
Submission made on the following:
Micro-credential approval and accreditation
Skill standards
Qualification and micro-credential listing
Offshore programme delivery
Programme approval and accreditation rules
Quality assurance rules
Disability Enrolment Questions October 2022
Submission made on the wording of changes to questions asked of enrolling tertiary students about their disabilities and support requirements
