Regulatory Standards Bill

Name: Simon Clark, Júlia Pásztor, Maddie Jardine
Role: Officers
Organisation: Aotearoa New Zealand Employed Veterinarians Union Manatōpū Inc (50223645) (NZBN: 9429052544569) [Incorporated Society] - henseforth, the Aotearoa Veterinarians’ Union, or AVU

Introduction
The Aotearoa Veterinarians’ Union is a voice for employed veterinarians across the motu. We advocate for fair and sustainable employment, science-led regulation, and the protection of animal welfare and public health.
As an organisation, we are committed to upholding Te Tiriti o Waitangi as a foundational and living document. Our constitution recognises that supporting Te Tiriti is a matter of tikanga, and we affirm the mana motuhake of tangata whenua. We approach all matters of public policy, including this submission, through that lens of partnership, equity, and respect for Māori rangatiratanga.

We submit this statement to express our deep concerns about the Regulatory Standards Bill (RSB), particularly its potential to undermine science-informed regulation, weaken animal welfare and public health protections, risk frameworks supporting fair trade, and marginalise both professional and Māori voices in the shaping of law.

Key Points of Concern
1. Undermining Professional and Scientific Consultation
Veterinary professionals are charged with protecting the health and wellbeing of animals, humans, and the environment. This work is grounded in science, ethics, and law. We are concerned that the Bill, by prioritising abstract regulatory principles over practical expertise, risks eroding the long-standing expectation that regulations impacting veterinary practice will be developed in consultation with the profession. This includes, and is not limited to:

●Public health measures to control zoonoses.
●Veterinary medicine prescription frameworks.
●Animal welfare standards.
●Fair domestic and international trade.
●National and community driven work safety protections for innately high risk and dangerous working environments.

Excluding or devaluing expert consultation in the name of efficiency risks serious, real-world consequences for animal and human lives.

2. Disproportionate Empowerment of Commercial Interests
The Bill creates a regulatory environment in which large commercial actors, such as pharmaceutical companies, commercial pet breeders, and veterinary clinic corporates, may be empowered to challenge regulation that restricts profit, even if that regulation serves a crucial public health, animal welfare, or fair trade purpose.
We are particularly concerned that:

●Prescribing rights and medicine access could be contested.
●Ethical standards of breeding and animal care may be undermined.
●Commercial interests may begin to shape veterinary and agricultural regulation to suit profit motives.

This would place veterinarians in ethically compromised positions and undermine both public trust and professional integrity.

3. Marginalising Te Tiriti and Tikanga Māori
The Bill contains no recognition of Te Tiriti o Waitangi, nor any mechanism to ensure tangata whenua have a role in the development or review of regulations. This is in direct conflict with the principles of partnership and equity that must underpin all lawmaking in Aotearoa.

If enacted, the Bill could:

●Disempower Māori in regulatory processes that affect whenua, wai, and taonga species.
●Undermine existing protections informed by tikanga and mātauranga Māori.
●Contradict the commitments that many agencies, including the veterinary profession, have made to genuine Tiriti partnership.

Any legislative framework that fails to uphold Te Tiriti is, by definition, unjust.

4. Chilling Effect and Legal Uncertainty
The Bill’s abstract regulatory principles may invite litigation, dissuade necessary regulatory reform, and create confusion among agencies tasked with protecting health and safety. Veterinary, biosecurity, and welfare laws must be responsive, not frozen by fear of failing a regulatory "checklist"


Foundational Concerns: Regulatory Principles and Power Centralisation

While we offer specific recommendations below, we must first express serious concern about two structural aspects of the Bill that fundamentally compromise the integrity of Aotearoa’s regulatory system.

1. Misaligned Regulatory Principles (Subpart 1, Section 8)
The proposed “principles of responsible regulation” are rooted in narrow interpretations of legal liberalism—emphasising economic liberties, individual property rights, and abstract procedural norms. These principles do not reflect Aotearoa’s constitutional realities, particularly Te Tiriti o Waitangi, nor do they account for public good, environmental protection, or mātauranga Māori. Without grounding in Tiriti obligations or One Health values, these principles risk undermining regulation that serves collective wellbeing, scientific integrity, or tangata whenua rights. As a foundational component of the Bill, this section must be entirely rewritten to reflect the legal and ethical commitments of our nation.

2. Dangerous Centralisation of Power (Subpart 2)
The Bill grants extraordinary power to a single Minister—chosen by the government of the day—to appoint members of the Regulatory Standards Board without meaningful checks, public consultation, or requirements for professional or scientific expertise. This Board would be empowered to assess, influence, and potentially veto primary and secondary legislation across all sectors, based solely on the misaligned principles described above. This represents a radical departure from our current framework, in which regulatory boards (such as the National Animal Welfare Advisory Committee) operate with expert membership, statutory constraints, and limited scope. No existing MPI-linked body possesses the sweeping authority envisaged here. To consolidate this much interpretive and gatekeeping power in a politically appointed body is not only undemocratic—it risks undermining trust, transparency, and sectoral engagement across the board.

Unless both these issues—the flawed regulatory principles and the unchecked concentration
of authority—are resolved at the structural level, the recommendations we outline below
cannot achieve their purpose. Reform must begin with these foundations.


Recommendations
1. Explicit Inclusion of Te Tiriti o Waitangi Obligations
Amend the Bill to include a statutory requirement to uphold the principles of Te Tiriti o Waitangi, and to ensure meaningful partnership with Māori in the development and review of regulations.

2. Safeguards for Scientific and Professional Expertise
Protect the role of registered professionals—especially in health, science, and welfare fields—in both the creation and review of regulations that affect their practice.

3. Exempt Critical Health and Welfare Legislation
Carve out core regulatory frameworks—such as the Animal Welfare Act, ACVM Act, Biosecurity Act, and Health Act—from the Bill’s scope, or provide for a higher threshold before such laws are subject to challenge.

4. Substantially Rewrite or Withdraw the Bill
Given the scale of concern raised by professionals, Māori organisations, unions, and environmental advocates, we recommend that the Bill be substantially rewritten or withdrawn entirely.


Conclusion
As veterinarians, we are stewards of wellbeing, not only for animals, but also for people and our shared environment. Our profession stands on the pillars of science, ethics, and public service. These must not be undermined in the name of regulatory convenience.
As a union, the AVU also affirms that Te Tiriti o Waitangi is not optional. A just regulatory system must honour that covenant and uphold the mana of tangata whenua.
We call on the Committee to reject this Bill in its current form and to commit instead to a process of regulatory reform that is inclusive, evidence-based, and Tiriti-honouring.

Nā mātou, nā,
Simon Clark, Júlia Pásztor, Maddie Jardine
Officers
Aotearoa New Zealand Employed Veterinarians Union Manatōpū Inc.