New Zealand Banking Association Code of Banking Practice¶


Regulator	New Zealand Banking Association
Jurisdiction	NZ
Status	live
Applicability	Platform

The New Zealand Banking Association (NZBA) Code of Banking Practice is a voluntary code subscribed to by all NZBA member banks. It sets minimum standards for treating customers fairly, providing clear and transparent product information, supporting customers in financial difficulty, and handling complaints. The Code is not legislation but breach of its commitments may be raised in complaints to the Financial Services Complaints Limited (FSCL) and cited by regulators when assessing conduct standards under the Financial Markets Conduct Act 2013 and the Customer and Product (CoFI) obligations. Banks are audited against the Code periodically by the NZBA.

The 2022 edition of the Code introduced strengthened obligations for vulnerable customers (including elder financial abuse protocols), plain language requirements, and proactive hardship identification. The Code applies across all personal and small business banking services offered in New Zealand.

Compliance register¶

This register maps the Code's material commitments to platform controls and institutional processes.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.
N/A	Obligation does not apply to this deployment configuration.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

Fair treatment and conduct¶

Commitment	Scope	Policy	Platform controls	Build
Treat customers fairly, honestly, and with respect; act in good faith in all dealings	🤖 Automated	CON-001	MOD-040 (AUTO) — at-risk customers proactively identified and contacted; fair conduct met before customer disengages. MOD-078 (AUTO) — spending limits and card controls set and visible to the customer in real time	🔨
Do not use unfair, high-pressure, or misleading sales practices	🤖 Automated	CON-001	MOD-051 (AUTO) — automated actions executed exactly as customer configured, no discretionary deviation; MOD-083 (AUTO) — compliance coaching nudges surfaced to agents in real time during interactions to prevent conduct breaches	🔨
Manage conflicts of interest to avoid customer harm	🏛 Institutional	CON-001	Conflicts of interest governance is institutional. MOD-083 logs agent-customer interactions against the interaction record	🔨

Information and disclosure¶

Commitment	Scope	Policy	Platform controls	Build
Provide clear, plain language information about products and services before a customer enters into an agreement	🤖 Automated	CON-004, CON-005	MOD-050 (GATE) — disclosure obligation met before every product acceptance; system enforces, no agent required. Fee disclosure shown before any fee-generating action	🔨
Notify customers of material changes to fees, charges, and product terms with adequate advance notice	🤖 Automated	CON-005	MOD-110 (GATE) — fee posting blocked if the required advance notice period has not elapsed since the fee schedule was last changed	🔨
Provide customers with access to their transaction history and account information	🤖 Automated	CON-001	MOD-051 (AUTO) — customers can view and manage their account and transaction history; account status changes reflected immediately	🔨

Financial hardship¶

Commitment	Scope	Policy	Platform controls	Build
Proactively identify customers experiencing financial difficulty and provide information about hardship assistance	🤖 Automated	CON-008, CON-003	MOD-065 (AUTO) — routes customers who meet hardship criteria into the hardship assessment workflow with appropriate communications triggered. MOD-040 (ALERT) — financial stress signals in the customer health score trigger a vulnerable customer flag	🔨
Provide practical assistance to customers who are experiencing genuine financial hardship, including repayment arrangements	🤖 Automated	CON-008	MOD-007 (AUTO) — hardship flag triggers account to Protected state; collections activity suppressed automatically	🔨
Do not pursue collection activity against a customer while a genuine hardship request is being considered	🤖 Automated	CON-008	MOD-007 (AUTO) — Protected state enforced at the account level; collections modules cannot action a Protected account	🔨

Complaint handling¶

Commitment	Scope	Policy	Platform controls	Build
Handle complaints promptly and fairly; provide customers with information about the complaints process and their right to escalate to the FSCL	🤖 Automated	CON-002	MOD-053 (ALERT) — IDR SLAs enforced automatically; agent cannot ignore a case past SLA without triggering escalation. MOD-083 (AUTO) — IDR complaint obligations surfaced to the agent in real time during customer interactions	🔨
Maintain a complaints register and report to the NZBA annually	📊 Evidenced	CON-002	MOD-053 (LOG) — complaint register maintained automatically; feeds the regulatory complaints report	🔨

Card security and online banking¶

Commitment	Scope	Policy	Platform controls	Build
Reimburse customers for unauthorised card transactions where the customer was not at fault	🏛 Institutional	PAY-005	Reimbursement decisions are institutional (fraud operations team). MOD-144 (GATE) — payee name verification reduces misdirected payments. MOD-078 (GATE) — card freeze executed immediately from the app; compromised card removed from the fraud attack surface without delay	🔨
Provide customers with tools to manage card and account security	🤖 Automated	PAY-005	MOD-078 (GATE) — instant card freeze from the app removes a compromised card without call centre involvement. MOD-007 (GATE) — fraud-flagged accounts automatically restricted pending investigation	🔨

Restricted activities (NZ banking law compliance)¶

Commitment	Scope	Policy	Platform controls	Build
Comply with restrictions on bank activities under NZ banking law; ensure products and features classified as restricted activities have required RBNZ consent before activation	🤖 Automated	GOV-010	MOD-146 (GATE) — restricted activity classification enforced at the product configuration layer; restricted products cannot be enabled without documented RBNZ consent or board resolution	🔨

Institutional obligations (not platform scope)¶

Obligation	Owner	Platform evidence input
NZBA Code audit — periodic review of compliance against the Code	Chief Compliance Officer	MOD-053 complaint register; MOD-047/MOD-083 agent interaction logs; MOD-050 disclosure acknowledgement records
Staff training on Code commitments	Chief People Officer	Institutional LMS
Annual reporting to NZBA	Chief Compliance Officer	MOD-053 complaint data; MOD-037 compliance report data
Unauthorised transaction reimbursement decision-making	Head of Financial Crime / Head of Operations	MOD-144 payee verification; MOD-078 card controls evidence

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊	Institutional 🏛
Fair treatment	3	2	0	1
Information and disclosure	3	3	0	0
Financial hardship	3	3	0	0
Complaint handling	2	1	1	0
Card and online security	2	1	0	1
Restricted activities	1	1	0	0
Total	14	11 (79%)	1 (7%)	2 (14%)

All attributed modules are currently build_status: Not started.

Policy	Title
CON-001	Customer Fairness & Conduct Policy
CON-002	Complaints & Internal Dispute Resolution Policy
CON-003	Vulnerable Customer Policy
CON-004	Product Disclosure & Sales Practice Policy
CON-005	Fee & Pricing Transparency Policy
CON-008	Financial Hardship Policy
GOV-010	Restricted Activities Policy
PAY-005	Payment Fraud Prevention Policy

Official documentation¶

Policies referencing this standard¶

CON-001 — Customer Fairness & Conduct Policy
CON-003 — Vulnerable Customer Policy
CON-005 — Fee & Pricing Transparency Policy
CON-008 — Financial Hardship Policy
CRE-009 — Fixed-Rate Component Break-Cost Methodology Policy
GOV-010 — Restricted Activities Policy
PAY-005 — Payment Fraud Prevention Policy

Compiled 2026-05-22 from source/entities/regulations/nz-banking-code.yaml