Submission to NZ Transport Agency Waka Kotahi Proposed changes to modernise NZTA services
Download the PDF of submission HERE
To: rules@nzta.govt.nz
Subject: Submission - Proposed changes to modernise NZTA services
Submissions close 12 August
Kia ora,
Please find below DECA's submission on the proposed changes to modernise NZTA services.
About DECA
Digital Equity Coalition Aotearoa (DECA) is a hub for the digital inclusion community in Aotearoa. We connect and support those working to close the digital divide. Our work uses the iMASTS framework, Identity, Motivation, Access, Skills, Trust, and Safety, to look beyond whether a digital service is only technically available, to whether people can actually use it with confidence.
We're responding because digital driver licensing touches identity infrastructure that has flow-on effects for how people prove who they are more broadly, and because several of the questions raised here echo patterns of assumed access to high spec devices and or data plans we're tracking elsewhere in government digital service design.
General comments
We want to acknowledge that this consultation is more attentive to access barriers than some other recent digital service consultations we've seen. Naming "access issues for some people" and "people without smartphones" directly in the survey questions (P1.3, P2.8, P3.3) is a genuine step forward.
That said, using the iMASTS framework, the proposals are built almost entirely around Access and system-level Trust (security, encryption, verification), with Motivation, Skills, and relational Trust left largely unaddressed. We've set out where those gaps show up below.
P1.3: In what ways, if any, could a digital driver licence create problems?
Access issues for some people
We'd broaden this category. The barrier isn't just having a smartphone, it's having one recent and capable enough to run the credential wallet. Setting up a digital wallet requires a device with biometric capability (face recognition or fingerprint) and app support is limited to the current and two previous major versions of iOS and Android. A working phone that's a few years old may already fall outside this. Device affordability is already a documented barrier for people DECA works alongside, being unable to afford an appropriate device is now one of the criteria Stats NZ uses to measure material hardship.
This also raises a practical question about battery and charge. A physical licence works regardless of whether it's charged. A digital one, particularly when producing it to Police at the roadside, depends on the phone having enough charge to unlock and open the app. We'd ask whether this has been considered as part of the safety and reliability analysis, not just device ownership, but device readiness at the point it's actually needed.
Setting up the wallet itself is a further skills barrier, not just a technical or device one. It requires completing an identity verification process correctly, and we regularly hear that people with lower digital confidence find this kind of setup difficult to complete unsupported. In practice, this creates pressure on organisations like Citizens Advice Bureau, who are often the ones people turn to for help getting through steps like this, without the corresponding resourcing to do so.
There's also an ongoing data cost to using these apps, downloading them, keeping them updated, and completing verification steps like RealMe checks (RealMe requires an active connection at the point of use, it isn't something that can be done offline), all draw on a mobile data plan. This consultation doesn't address data affordability anywhere.
P1.4: Are there any issues with the proposed draft Rule that we should consider?
Yes.
Skills demand in the Police verification scenario
The document specifies that a driver isn't required to hand over their device to Police, they keep hold of it and share the licence electronically. That's a sound design choice. But it still requires the driver to complete a multi-step interaction correctly, unlock the phone, open the app, navigate to the right credential, and follow prompts to share the required information, at the roadside, under time pressure, in front of an officer.
This is a materially different skill set to producing a physical card, and it hasn't had the benefit of the years of routine, low-stakes practice that using a physical licence has. We'd like to see this factored into rollout planning, including whether community organisations, who are often the ones people turn to for practical digital support, are resourced to help people build confidence and competence with a digital driver licence before they need to use it under pressure.
No consideration of motivation or trust in adoption
The consultation assumes people will want to move to a digital driver licence given the convenience gains on offer. It doesn't ask why some people might choose not to, even where they're fully able to. Trust in carrying a legal identity credential on a personal device, one subject to battery life, software updates and app permissions, is a different kind of trust to the security architecture NZTA has described. We'd encourage NZTA to treat ongoing willingness to use a DDL as something to monitor, not something to assume.
Device tier as a hidden threshold
The consultation frames access risk in terms of smartphone ownership generally, but the actual requirement is narrower: a smartphone recent enough to be within its OS support window, and capable of biometric authentication. This excludes a meaningfully larger group than "no smartphone" alone, including people using older but otherwise functional devices. We'd like to see this named explicitly in NZTA's access analysis, rather than assumed away under a general smartphone ownership question.
Brower based options
We'd also ask whether a browser-based option is being considered alongside app-based verification and wallets, for both holding and checking a digital driver licence. NZTA's own proposal for vehicle compliance checking already supports a web-based path in addition to an app, and we'd encourage the same approach for driver licences. Requiring a dedicated app for something previously achievable with a physical card in a wallet adds another piece of software people need to install, trust, and keep updated, on top of the growing number of separate government apps already in use.
P2.1: Do you agree with the proposal to let the Director of Land Transport set the information required for driver licensing applications (other than first time applicants) and the list of accepted identification documents?
Yes, with some concerns.
We support the flexibility this gives NZTA to keep identification requirements current. Our concern is about visibility and communication when these requirements change. People who rely on community organisations, budgeting services, or social service providers to help them navigate licensing applications need those organisations to know what's currently accepted, in practice this depends on timely, plain-language publication whenever the Director updates a transport instrument, not just publication in principle.
P2.2: Do you agree with the proposal to enable the use of the RealMe verified identity credential for online driver licence applications?
Yes, with concerns.
RealMe verified identity is described as the only digital credential currently available with an acceptable level of assurance, which we understand reflects a genuine current limitation rather than a preference. Our concern is that RealMe verified identity itself depends on an existing high-assurance identity trail, something not everyone has equal access to establishing in the first place. People without an existing RealMe verified identity are pushed entirely to the in-person pathway for now. We'd like to see this treated as a temporary state to actively work beyond, with a clear plan for what "other government identity credentials" might follow, rather than an endpoint.
P2.5: Do you support enabling online learner theory testing?
Yes, with some concerns.
We support the underlying access principle. Removing the requirement to travel to an AA or VTNZ site for the learner theory test would reduce a real barrier for people in rural areas, without reliable transport, or juggling work and caregiving commitments. We note the draft Rule keeps in-person testing available as a standing option alongside online, rather than replacing it, which addresses part of our concern.
Our remaining concern is that the proposal doesn't yet specify what the identity checks and fraud controls for the online option would involve, so it's difficult to assess the skills and safety implications at this stage, an online test that layers verification or proctoring requirements on top of the test itself could work against learners with lower digital confidence or literacy, or those without a private, suitable space to sit a monitored test at home. Depending on the fraud control approach chosen, this could also require a specific level of device, a working camera for live proctoring, for example, which raises the same device tier question we've flagged in P1.3, and shouldn't become a barrier for someone with an older or more basic phone.
We'd also ask that data cost be considered in the design, an online test with live proctoring or continuous verification could use a meaningful amount of mobile data, on top of the same affordability barrier we've raised in P1.3, and this shouldn't become a second cost of entry for a test that's currently free to sit in person. We'd ask to be consulted separately once the identity verification and fraud control design is developed.
P2.9: Are there any issues with the proposed drafting that we should consider?
Yes.
We note this approach already exists for passport applications, where a self-captured photo (taken by someone else, not a selfie) is accepted if it meets specific format requirements, checked using a free online photo checker before submission. In practice, applications are delayed when a submitted photo doesn't meet requirements. We'd ask whether NZTA is planning for the same failure point, what happens for someone applying for their first driver licence when a self-captured photo doesn't pass, who helps them resolve it, and whether there's a risk of repeated delay for people without confident access to a smartphone camera, a second person to take the photo, or reliable connectivity to resubmit.
P3.3: In what ways, if any, could this proposal create problems?
We'd highlight two, alongside the checklist options: technology or reliability risks, and access issues for some people.
The first is a practical point about the verification tooling itself. NZ Verify, the app intended to support electronic checks, works offline but needs to reconnect within three days to keep its trusted credential list current. In areas with patchy or intermittent connectivity, that has implications for how reliably electronic checks can actually be performed at the point of need, not just for the vehicle owner but for whoever is doing the checking.
The second is about who bears the burden of checking. Electronic verification assumes the checking party, whether that's an individual, a smaller community organisation, or a business, has a suitable device and enough confidence to install and use verification tooling correctly. We'd encourage NZTA to consider this alongside the vehicle owner's access, not just as a one-sided question of whether the licence holder has a smartphone.
Closing
We're happy to discuss any of the above further, and would welcome the opportunity to stay engaged as NZTA's digital driver licence work progresses, particularly on how identification requirements and accepted credentials evolve over time.
Ngā mihi, Marie Silberstein, DECA (Digital Equity Coalition Aotearoa)
kiaora@digitalequity.nzdigitalequity.nz
