Bill Payment Services
- Marketing
- May 15
- 2 min read
Updated: May 16

In New Zealand, there isn't a specific mandatory registration solely for providing "bill payment services" in isolation. However, entities offering bill payment services are likely to fall under broader regulatory obligations within the financial services landscape. Here's a breakdown of the key considerations:
1. No Specific License for Bill Payment Services:
The Financial Markets Authority (FMA) has clarified that there isn't a specific license for e-money institutions or payment service providers in New Zealand. This includes bill payment services.
2. Obligations under the Financial Markets Conduct Act 2013 (FMC Act):
Fair Dealing Provisions: Providers must comply with Part 2 of the FMC Act, which prohibits misleading or deceptive conduct and false representations when supplying financial services.
Financial Service Providers Register (FSPR): It's highly likely that bill payment service providers offering services to retail clients in New Zealand would need to register on the FSPR. Registration indicates that the provider is subject to certain regulatory oversight.
Dispute Resolution Scheme: If services are provided to retail clients, providers will likely need to be a member of an approved dispute resolution scheme to handle complaints.
3. Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act):
Bill payment service providers are very likely to have obligations under the AML/CFT Act. This includes:
Customer Due Diligence: Verifying the identity of their customers.
Risk Assessment: Assessing the risks of money laundering and terrorism financing within their business.
Compliance Programme: Implementing procedures to detect, deter, manage, and mitigate these risks.
Suspicious Activity Reporting: Reporting any suspicious transactions to the Financial Intelligence Unit (FIU).
Record Keeping: Maintaining appropriate records of transactions and customer information.
4. Retail Payment System Act 2022:
This act allows the Commerce Commission to monitor and regulate the retail payment system, which includes various payment networks. While the immediate focus has been on card networks, future regulations could potentially impact bill payment services, especially if they utilize designated networks.
5. Reporting Requirements to Inland Revenue Department (IRD):
Payment Service Providers (PSPs), which would likely include bill payment services, may have reporting obligations to the IRD regarding merchant income data. However, the IRD guidance specifically mentions that "exempt transactions such as direct debits, automatic payments or bill payments" do not need to be included in these reports at this time. This suggests that while direct bill payments might be currently exempt, the broader category of payment services has reporting obligations.
In Conclusion:
While there isn't a specific registration obligation solely for "bill payment services" in New Zealand, providers of these services will almost certainly need to comply with broader regulations such as registration on the FSPR and obligations under the AML/CFT Act. Depending on how the service operates and interacts with the wider payment system, the Retail Payment System Act may also become relevant.
It is crucial for any entity offering bill payment services in New Zealand to seek legal advice to fully understand their specific regulatory obligations based on their business model and the types of services they provide.
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