RUC on Rails Submits on New Zealand’s Proposed RUC Regulations

Today on June 12th 2026, RUC on Rails submitted its response to the Ministry of Transport’s consultation on the proposed regulations for New Zealand’s future Road User Charges system.

The consultation follows the Land Transport Revenue Amendment Bill’s first reading and consideration by Parliament’s Transport and Infrastructure Committee. The Committee reported the Bill back to Parliament on 18 May 2026, with the Bill now expected to progress through its remaining legislative stages before coming into force in early 2027.

The proposed regulations sit beneath the Bill and will help determine how the future RUC provider market operates in practice, including how providers are approved, monitored, and permitted to offer new payment, retail, technology, and distance-recording services.

We support the overall direction of the reform, including the separation of NZTA’s collector and provider roles and the move toward performance-based, outcomes-focused regulation.

Our submission responds to all 12 consultation questions and focuses on four principles: technology-neutral standards, proportionate regulation, privacy by design, and greater implementation certainty for prospective providers.

“The legislation establishes the broad shape of the future market, but the regulations will determine whether that market actually becomes competitive, accessible, and capable of supporting ordinary light-vehicle owners,” says Adam Johnston, founder and CEO of RUC on Rails.

Keeping hardware optional for light vehicles

A major focus of our submission is electronic distance recording.

We strongly support different standards for light and heavy vehicles. Heavy commercial fleets have fundamentally different engineering, compliance, and operational needs from privately owned light vehicles.

For most light vehicles, we believe the existing vehicle odometer should remain the mainstream distance record. Drivers should be able to enter their plate, confirm an odometer reading, and purchase RUC without being required to install GPS, telematics equipment, or another dedicated device.

Our consumer research found strong resistance to compulsory tracking and in-vehicle hardware, with privacy and cost emerging as the leading concerns.

“Technology-neutral regulation should not simply mean choosing between different tracking systems,” says Johnston.

“It should preserve a genuine no-additional-device option for ordinary drivers. Telematics can remain available for people who actively want automation, but it should not become the default.”

Provider approval, competition, and retail access

The submission broadly supports the proposed approval criteria for future RUC providers, including financial integrity, secure systems, privacy compliance, and the separation of RUC revenue from providers’ own funds.

However, we have asked for these requirements to be applied proportionately and according to the risks of each provider model.

A prepaid software provider, an alternative payment operator, a telematics business, and a provider working through retail agents do not create identical risks and should not automatically face an identical approval process.

We also raised the need for clearer rules governing RUC agents. Retailers, payment companies, and other distribution partners need to understand their responsibilities before committing to future in-person and over-the-counter RUC services.

Stronger privacy protections

Our submission argues that the proposed privacy requirements are a solid starting point, but do not go far enough.

Protecting information after it has been collected is important. Preventing unnecessary information from being collected, commercialised, or shared in the first place is equally important.

We have recommended stronger data-minimisation requirements, restrictions on unrelated commercial use and third-party sale, clearer retention rules, and a privacy-preserving default for light vehicles.

Public concern about GPS tracking is already one of the most significant risks facing the RUC transition. Strong and visible privacy safeguards will be essential to maintaining trust and preventing misinformation from defining the system before it launches.

Making alternative payment schemes commercially workable

We support alternative payment models, including automated purchasing, account-based services, and post-payment options.

However, the current proposals do not yet provide enough information about settlement cycles, processing fees, failed payments, fraud, chargebacks, or how liability will be divided between providers, payment companies, retailers, customers, and NZTA.

These details will determine whether alternative payment schemes are commercially workable, rather than merely permitted on paper.

RUC transactions also create a particular payment challenge because most of the customer’s payment is Crown revenue, yet standard card-processing fees are charged against the full transaction value.

We have asked the Ministry to provide clearer commercial settings and support lower-cost payment pathways suitable for a high-volume, low-margin public revenue system.

The market needs certainty to become ready

The Government has indicated that the wider transition of petrol vehicles will depend partly on the availability, quality, and adoption of private-sector RUC services.

Our closing point is therefore straightforward: the private sector cannot demonstrate readiness without enough information to build against.

Prospective providers still require clarity on application dates, approval timelines, technical standards, access to NZTA systems, API costs, settlement rules, provider fees, agent requirements, and the future Code of Practice.

“The Government intends to assess whether the market is ready, but the market cannot become ready while the specifications it needs remain unpublished,” says Johnston.

“The willingness to participate is already there. What the industry needs now is enough certainty to finish building, secure partners, and prepare properly.”

Our full consultation submission on the proposed Road User Charges regulations can be viewed here:

[Read our full consultation submission here.]