Have your say on RUCs (Road User Charges), privacy and freedom of movement

The Government is consulting on proposed regulations for New Zealand’s modernised Road User Charges system.

These changes are being presented as a fairer and more convenient way to fund roads as more vehicles become electric, hybrid, or fuel-efficient.

However, the proposals raise serious questions about privacy, digital surveillance, private providers, data sharing, app-based systems, built-in vehicle technology, climate policy, future expansion of the RUC system, and whether New Zealanders will still have simple, non-digital and non-tracking ways to pay.

The deadline for providing feedback on the RUCs consultation is Friday 12 June 2026, 5pm.

We understand many people wish to provide feedback, but with limited time and a lot of conflicting or confusing reporting, there’s uncertainty around how best to be heard.

Providing even very brief feedback is worthwhile. The strongest feedback will be written in your own words, reflecting your own concerns, family situation, work, business, farming, regional transport needs, privacy concerns, or views as a New Zealander.

The deadline for feedback is Friday 12 June 2026, 5pm

You can provide feedback:

By email: (This is probably the easiest option at this stage.) Simply choose options from the template below and email them in.

Email to: [email protected]

Subject line: Road User Charges Regulation Proposals – Feedback. Include your name and contact details.

OR

Use the online form: https://consult.transport.govt.nz/policy/proposed-regulations-for-road-user-charges/

On the above link, scroll down to click “Share your views” to put in your feedback. NOTE: The consultation document includes specific questions to guide submissions, but you do not need to answer every question. You can comment on any part of the proposals or raise other issues you think are important.

Suggested feedback template:

You can use this template below as a starting point. Use one or more of the following in your responses or any of the additional information shared following this template. But remember – just ONE paragraph of your choice from any of the below will do!

I am concerned about the proposed Road User Charges regulations.

• I support fair road funding, but I do not support any system that forces New Zealanders into digital tracking, app-based accounts, GPS-linked devices, built-in vehicle monitoring, subscription-style payment systems, or private provider accounts simply to drive.
• Travel data is highly sensitive. It can reveal where people work, who they visit, what services they use, what medical appointments they attend, what political or community activities they take part in, and how they live their private lives.
• I am concerned that the proposed system could collect, store, share, or enable access to more information than is necessary to calculate road user charges.
• I am also concerned that the system could later be expanded beyond road funding and used for climate policy, emissions management, congestion charging, smart-city planning, digital identity systems, transport behaviour change, or other forms of movement monitoring or control.
• I am also concerned that infrastructure created for road-user charging today could become the foundation for wider digital monitoring, location-based charging, behavioural incentives, digital identity integration, or other future systems that have not yet been fully debated by Parliament or the public.
• I acknowledge that these uses are not currently proposed in the regulations. However, once digital infrastructure is established, future governments may seek to expand its use. For that reason, strong safeguards should be built into the system from the outset.

I recommend that the regulations be changed to:

• guarantee simple non-digital, non-app-based and non-tracking payment options;
• prohibit unnecessary GPS, location or real-time movement tracking, and require distance-only systems wherever possible;
• minimise data collection, strictly limit information sharing, and require data to be deleted when no longer needed;
• prohibit the sale, monetisation, profiling, commercial use, or creation of travel profiles beyond what is necessary to calculate and collect RUC;
• prevent RUC data being used for climate-policy enforcement, emissions rationing, travel demand management, movement restriction, advertising, insurance profiling, credit decisions, political monitoring, or unrelated enforcement activities;
• require full transparency about what data is collected, who holds it, who can access it, where it is stored, and how long it is retained;
• require independent privacy and cybersecurity audits, together with public privacy and civil-liberties impact assessments before implementation;
• ensure rural, regional, farming, trade, disability, caregiving and low-income households are not unfairly burdened;
• prohibit integration with digital identity systems, digital wallets, digital credentials, digital driver licences, CBDCs, programmable money systems, behavioural scoring systems, or similar mechanisms unless expressly authorised by future primary legislation following full public consultation;
• require any expansion of RUC beyond road funding, including location-based charging, time-of-use charging, congestion charging, emissions-based charging, behavioural pricing, or other secondary uses, to be approved by Parliament through primary legislation following full public consultation.

New Zealanders should not be required to surrender privacy, anonymity of lawful movement, or freedom from unnecessary surveillance in order to use the road network.

If the Government wishes to modernise road funding, it should do so using the least intrusive technology possible and with strong safeguards against future function creep.

I ask that the proposed regulations be substantially amended before proceeding.

Expanded list of concerns on the proposals:

The following are among the key concerns raised about the proposed regulations and the wider shift toward RUC for all vehicles. You may like to use these points in your feedback.

Privacy and tracking

Freedom of movement is a protected right under section 18 of the New Zealand Bill of Rights Act 1990.

Travel data is sensitive. It can reveal where people work, when they leave home, who they visit, what medical services they attend, where they worship, what political or community activities they take part in, how often they travel, and how they live their private lives.

The proposed system involves electronic distance recording, approved RUC providers, alternative payment schemes, data management, auditability, compliance, and information sharing. The concern is that road charging could become more than road charging. It could become a system capable of monitoring private movement.

Built-in vehicle technology & app-based systems

The Government presents the changes as convenient. Drivers may no longer need paper RUC labels. The system may allow built-in vehicle technology, electronic devices, monthly billing, subscription-style payments, and bundled tolls and charges.

Convenience may suit some people, but it should not become coercion. No New Zealander should be forced into an app, digital account, GPS-linked device, built-in vehicle monitoring system, or private provider account simply to drive.

Non-digital & non-tracking options

A fair system must include simple non-digital, non-app-based and non-tracking ways to pay.

Many people do not want their travel linked to an app, digital wallet, private provider account, vehicle manufacturer system, or government digital identity infrastructure. Others may not have reliable internet, a smartphone, or the ability to manage app-based or subscription-style systems.

Driving is part of ordinary life. It should not require digital participation.

Private providers & road-user data

The proposed framework allows approved RUC providers to play a major role in issuing licences, collecting charges, administering payment schemes, handling complaints, and managing information.

That creates obvious questions: Who will hold the data? Where will it be stored? Who can access it?

Can it be shared with government agencies, police, insurers, advertisers, vehicle manufacturers, data companies, or overseas contractors? Can it be used for anything other than calculating and collecting RUC? Can it be sold, monetised, profiled, or linked to other digital systems? These questions need clear answers before the regulations proceed.

Function creep

The Government says this is about fair road funding.

But RUC for all vehicles also sits within a wider policy environment where transport pricing, emissions reduction, climate targets, congestion charging, smart-city planning, travel demand management, data collection, and behaviour change are increasingly linked.

International organisations such as the United Nations, UNFCCC, OECD, and International Transport Forum have promoted transport pricing, digitalisation, data collection, emissions reduction, and travel demand management as part of “sustainable transport” policy.

The wider context matters. If the RUC system is only about road funding, the regulations should clearly say so and prohibit wider use. If the system is also intended to support climate policy, emissions management, congestion charging, smart-city planning, digital transport monitoring, or behaviour change, the public deserves to know that now.

History shows that digital systems are often expanded beyond their original purpose once the infrastructure is in place. It could be used to vary charges by vehicle type, time, route, location, emissions profile, congestion level, or other policy criteria.

That should not happen quietly through regulations, provider contracts, technical standards, or future scheme approvals.

Digital identity, digital wallets & future integration

The current consultation is focused on Road User Charges. However, once a nationwide digital road-charging infrastructure exists, many people are concerned about the possibility of future integration with other digital systems.

These concerns include:

• digital identity systems;
• digital driver licences;
• government apps;
• digital credentials;
• digital wallets;
• payment platforms;
• vehicle manufacturer systems; and
• other government or private-sector databases.

The consultation does not propose these integrations today. However, many New Zealanders want clear assurances that road-user charging will remain separate from broader digital identity or credential systems unless Parliament expressly approves such changes following full public consultation. Road charging should remain road charging.

Rural, regional and household impacts

Many New Zealanders cannot simply drive less.

Farmers, tradespeople, carers, shift workers, disabled people, rural and regional communities, families, and people with limited public transport options rely on private vehicles.

For many people, driving is not a lifestyle choice. It is how they get to work, care for family, attend appointments, buy food, run a business, and stay connected. A modernised RUC system must not unfairly punish people who have no realistic alternative to driving.

Optional additional points:

If you wish to provide more detail, you could choose to include some of the following points.

1. Electronic distance recorders

For light vehicles, the least intrusive option should be required.

Distance-only reporting should be the default. GPS tracking, real-time monitoring, or electronic recording of private movement patterns should not be allowed unless there is a clear, limited, lawful, and necessary reason.

There must be a clear legal distinction between recording distance for road charging and recording location or movement for wider purposes.

2. Outcomes-focused regulation

An outcomes-focused approach may sound flexible, but it can become too loose.

If providers are left to decide what technology is acceptable, “innovation” could become an excuse for GPS tracking, app-based monitoring, telematics, automated enforcement, behavioural profiling, or unnecessary collection of travel information. Privacy protection should be one of the required outcomes.

3. RUC providers

RUC providers should not be treated as ordinary retailers.

They may collect money, manage user accounts, administer payment schemes, handle complaints, use agents and subcontractors, and hold sensitive vehicle-use information. Any provider should have to prove strong privacy, cybersecurity, data minimisation, complaint handling, audit, and transparency standards before being approved.

A provider whose business model depends on extracting, profiling, selling, or reusing user data should not be approved.

4. Information sharing

Information sharing should be limited to what is strictly necessary for calculating, collecting, auditing, and enforcing RUC.

The regulations should clearly state:

• what information may be shared;
• why it may be shared;
• who may access it;
• how long it may be kept;
• whether it may be matched with other government databases;
• whether it may be used for purposes outside RUC;
• whether it may be shared with law enforcement or other agencies;
• what rights users have to challenge, correct, or complain.

The default should be that personal road-user information is not shared unless strictly necessary and legally justified.

5. Complaints and errors

RUC providers should be required to keep proper complaints records, but personal complaint information must be protected.

There should be clear timeframes for complaint responses, correction of errors, refunds, escalation, and independent review.

Aggregated complaint data should be published so the public can compare providers and identify recurring problems.

6. Privacy protection

General compliance with the Privacy Act is not enough.

The regulations should include specific road-user privacy protections, including:

• data minimisation;
• no unnecessary GPS or location tracking;
• clear data retention and deletion rules;
• independent audits;
• strong penalties for misuse;
• user access and correction rights;
• mandatory reporting of serious privacy breaches;
• limits on offshore data processing;
• limits on subcontractors, agents, vehicle manufacturers, and technology suppliers.

7. Climate policy and behaviour change

If this system is only about road funding, the regulations should say so clearly.

RUC data should not be used for climate-policy enforcement, emissions rationing, travel demand management, congestion charging, smart-city planning, movement restriction, or behaviour change unless Parliament expressly authorises that use through primary legislation after full public debate.

Transport pricing should not become a backdoor tool for controlling how, when, where, or why people travel.

8. Rural and regional fairness

Rural and regional New Zealanders often have no practical alternative to driving. Farmers, tradespeople, carers, shift workers, disabled people, families, and small businesses may be hit hardest by systems that are complex, expensive, digital-only, or based on assumptions that people can simply reduce travel or switch modes. The regulations must protect people who depend on private vehicles for ordinary life.

9. Digital identity and government apps

The RUC system should not be linked by default to digital identity, digital driver licences, digital wallets, government apps, or other digital credential systems. Road charging should remain limited to road charging. New Zealanders should not have to participate in wider digital government infrastructure just to drive.

10. CBDCs and financial surveillance

Some New Zealanders are concerned about the possibility that future digital payment systems could become increasingly interconnected.

The current consultation is not about Central Bank Digital Currencies (CBDCs).

However, because the proposals contemplate increased digitisation of road-user charging and payment systems, many people wish to see clear safeguards preventing future integration between road-user charging systems and any form of programmable digital currency, social-credit-style scoring, spending controls, or financial surveillance system.

Whether or not such systems are ever proposed, the public should not be expected to assume that future integration will never occur. Clear legal protections are preferable to political assurances.

11. What to ask for

You may wish to ask that the Ministry:

• pause the regulations until a full privacy impact assessment is published;
• publish a civil liberties impact assessment;
• guarantee non-digital and non-tracking options;
• prohibit unnecessary GPS and location tracking;
• prohibit commercial use of road-user data;
• strictly limit data sharing;
• prevent function creep;
• require independent audits;
• require public reporting of breaches, complaints, and provider performance;
• require any expansion beyond road funding to go back to Parliament.

Final message

Fair road funding should not require digital tracking or unnecessary surveillance, nor should it undermine the protected right to freedom of movement.

New Zealanders should not be forced into apps, digital wallets, GPS-linked devices, private provider systems, or built-in vehicle monitoring simply to drive.

The Government must protect privacy, freedom of movement, and practical choice from the start.