RUC on Rails Makes First Select Committee Submission on New Zealand’s Future RUC Provider Market

Today, RUC on Rails has made its first written submission to Parliament’s Transport and Infrastructure Committee on the Land Transport Revenue Amendment Bill.

The Bill has recently passed its first reading, and public submissions are now open ahead of its second reading. This stage gives organisations, industry participants, and members of the public an opportunity to provide feedback on how the proposed changes may operate in practice.

The Bill will establish the framework for a new private market of approved Road User Charges providers as New Zealand begins modernising and expanding the RUC system.

We support the overall direction of the Bill. Organisations that issue RUC licences and collect and forward road user charge revenue should be approved, accountable, and subject to strong regulatory oversight.

Our submission focuses on a more specific issue: the Bill defines who may become a RUC provider, but it does not clearly define where that responsibility ends.

Without clearer boundaries, retailers, software platforms, agents, technical partners, and other intermediaries could potentially be interpreted as RUC providers simply because they help a customer access or manage RUC.

“The future RUC system will not be delivered by one organisation doing everything from beginning to end,” says Adam Johnston, CEO of RUC on Rails.

“There will be approved providers, but there will also be retailers, payment networks, software platforms, agents, and service businesses helping people interact with those providers. The law needs to make it clear which organisation carries the regulatory responsibility.”

Why the RUC provider definition matters

As Road User Charges expand across the vehicle fleet, people will expect to access RUC through a much wider range of channels.

Some drivers may purchase RUC directly through a provider’s website or mobile application. Others may prefer to pay in person through a service station, dairy, convenience store, or another local retailer.

Businesses and fleets may appoint an accountant, compliance service, or other intermediary to manage RUC purchases on their behalf. RUC services may also be embedded within parking, vehicle-management, mobility, or transport platforms that customers already use.

These organisations may facilitate the transaction, but they do not necessarily issue the RUC licence, determine the applicable charge, or forward the revenue to NZTA.

Our submission argues that regulatory responsibility should remain with the approved RUC provider performing those core functions.

“This is not an argument for weaker regulation,” says Johnston. “It is an argument for putting the regulation in the right place.”

“The approved provider should remain fully responsible for licence issuance, revenue settlement, fraud prevention, auditability, and compliance. A retailer helping someone complete a purchase should not suddenly become responsible for operating a regulated RUC system.”

Three practical RUC delivery scenarios

Our submission provides three detailed scenarios showing how uncertainty around the definition of a RUC provider could affect the future market.

1. Over-the-counter RUC access through local retailers

Local retailers already provide access to services such as mobile top-ups, prepaid electricity, transport products, and other utility-style payments.

Under a similar RUC model, a customer could purchase RUC in person while an approved provider completes the licence transaction and remains responsible for the regulated service.

If every participating store faced the possibility of being treated as a RUC provider, most small retailers would be unable or unwilling to participate.

Becoming an approved provider is expected to require substantial technical capability, governance, security controls, auditing, and ongoing compliance. Those requirements are appropriate for the organisation issuing licences and settling revenue, but clearly unrealistic for a local dairy or independently owned service station.

This could significantly reduce in-person RUC access, particularly in rural and regional communities where local retailers remain an important point of service.

“Over-the-counter access cannot work if every shop involved is expected to become a regulated transport revenue provider,” says Johnston.

“That would not improve oversight. It would simply remove most retailers from the market and make RUC harder to access.”

2. Digital platforms embedding RUC access

RUC may also be offered through digital platforms that already help customers manage parking, tolls, vehicle access, mobility subscriptions, or other transport services.

In this type of arrangement, the platform provides the customer interface while the approved RUC provider issues the licence and settles the revenue with NZTA.

Our submission raises the concern that customer interaction or technical enablement could be interpreted too broadly.

Taken to an extreme, this could create uncertainty for general software providers, hosting platforms, integration services, or other technology businesses that support a RUC transaction without controlling the regulated activity.

The submission argues that the infrastructure enabling a service should not become regulated merely because a customer interacts with RUC through it.

“The customer interface is not always the provider,” says Johnston.

“A website, application, payment layer, or technical integration may help deliver the service, but the regulatory responsibility should sit with the organisation actually issuing the licence and accounting for the money.”

3. Intermediaries managing RUC on behalf of customers

Businesses commonly appoint third parties to manage registrations, licensing, statutory payments, and other compliance obligations.

A fleet operator, for example, may engage an accounting provider or managed compliance service to administer RUC purchases across its vehicles.

That intermediary may initiate a transaction and later recover the RUC cost from its client as part of a broader service invoice. However, it does not issue the licence or remit the RUC revenue to NZTA.

Our submission asks the Committee to confirm that delegated administration, facilitation, and cost recovery do not automatically make an organisation a RUC provider.

Without this distinction, ordinary agency and professional-service arrangements could become difficult or impossible to operate.

Supporting a competitive and innovative RUC market

The purpose of introducing private RUC providers is to create a more competitive and innovative market while preserving strong oversight of public revenue.

Our submission argues that innovation will often occur around the provider, particularly through new retail channels, payment options, software integrations, and customer experiences.

If every participant in that delivery chain is potentially captured as a RUC provider, the market may become limited to a small number of vertically integrated organisations capable of operating every component themselves.

That would reduce customer choice and discourage businesses from developing new ways for people to access and manage Road User Charges.

Clear boundaries would not dilute accountability. The approved provider would remain responsible to NZTA regardless of whether customers access the service directly, through a retailer, through a digital platform, or through an authorised intermediary.

“Our position is fairly straightforward,” says Johnston.

“The organisation that issues the RUC licence and forwards the revenue should carry the regulatory responsibility. The businesses helping customers reach that provider should not be captured unless they are also performing those regulated functions.”

What we have asked the Select Committee to clarify

Our submission recommends that the Committee clarify that:

1. RUC provider status applies to organisations that issue RUC licences and collect and forward RUC revenue to the RUC collector.

2. Retailers, agents, digital platforms, intermediaries, and technical partners are not RUC providers solely because they interact with customers or facilitate access.

3. Delegated execution, administration, and cost recovery do not transfer regulatory responsibility away from the approved provider.

4. General software, hosting, integration, and digital-interface providers are not captured simply because their technology is used to deliver a RUC service.

5. The Committee’s report should provide practical guidance on how the new framework applies across retail, digital, and intermediary delivery models.

The submission does not seek to redesign the Bill or reduce the obligations placed on approved providers.

It seeks clearer separation between the regulated core of the RUC system and the wider network of businesses that may help make that system accessible to the public.

As New Zealand moves toward a much larger RUC market, this distinction will be important for ensuring the system remains competitive, practical, and available through the channels drivers actually want to use.

Our full written submission to Parliament’s Transport and Infrastructure Committee was submitted on 25 December 2025.

Our full written submission can be found here -

RUC on Rails - Written Submission Parliament 2025

It includes our detailed recommendations and the three illustrative RUC delivery scenarios provided to the Committee.