Transparency is not only about making rules—it is also about explaining what happens when those rules are broken. Public confidence in financial regulation depends on people being able to see how regulators investigate misconduct, enforce the law, and communicate the outcomes of those actions.
TINZ's new report, Transparency in Practice, examines how New Zealand's three financial regulators—the Department of Internal Affairs (DIA), the Financial Markets Authority (FMA), and the Reserve Bank of New Zealand (RBNZ)—publicly report their enforcement activities between 2021 and 2026.
Drawing on a hand-compiled register of 40 enforcement actions, the report asks whether the public receives a consistent level of information, regardless of which regulator is acting.
The answer is nuanced.
The report finds that once an enforcement matter reaches the courts or results in a financial penalty, all three regulators are reasonably consistent in disclosing the outcome. However, the overall public picture differs significantly because each regulator relies on different enforcement tools. The FMA publishes proportionally more court proceedings and penalty decisions, while the RBNZ more commonly issues formal warnings. DIA sits between the two, but its enforcement information is dispersed across news releases, PDFs and court decisions rather than being available through a single searchable register.
One of the report's key findings is that apparent differences in transparency are often driven by the type of enforcement action being taken rather than by a regulator's willingness to disclose information. Court judgments naturally provide much richer public information than warnings or undertakings. Comparing regulators fairly therefore requires comparing like with like.
The report also identifies several practical improvements that would make enforcement more transparent and easier for the public to understand. These include comprehensive enforcement registers for each regulator, more consistent reporting of non-penalty outcomes, and a common taxonomy for describing breaches across the financial regulatory system.
With responsibility for financial regulation evolving, this report provides a timely benchmark for measuring transparency across regulated sectors. TINZ hopes it will contribute to ongoing discussions about how the Department of Internal Affairs can strengthen public accountability and confidence through clearer, more accessible enforcement reporting as it takes over all regulation of financial entities.
Read the report: Transparency in Practice: A comparative review of public enforcement disclosure by New Zealand's financial regulators, 2021–2026.
