Use and Development of Blockchain in the Last 12 Months

Blockchain adoption in New Zealand (NZ) remains cautious and incremental. Over the past 12 months, regulatory engagement and compliance developments have outweighed large-scale commercial deployment.

The Ministry of Business, Innovation & Employment (MBIE) Long-Term Insights Briefing on the Future of Business for Aotearoa New Zealand (the “MBIE Briefing Paper”) reaffirmed government interest in blockchain’s potential for supply chain integrity, digital identity and verifiable data, particularly in agriculture and health, but no new blockchain-specific policy was released.

Regulatory momentum has continued following the Report of the Finance and Expenditure Committee (FEC), August 2023 (the “FEC Report”), with more structured engagement between industry and the Financial Markets Authority (FMA) in 2025, signalling an intention to bring crypto-asset platforms within clearer supervisory boundaries. From a tax perspective, Inland Revenue (IRD) implemented the Crypto-Asset Reporting Framework (CARF) with effect from 1 April 2026, significantly increasing reporting obligations and transparency for crypto-asset service providers.

Consumer protection has remained a major focus. Crypto-related scams have continued at scale, prompting co-ordinated warnings and enforcement activity involving the FMA, IRD and the Department of Internal Affairs (DIA), reinforcing a regulatory emphasis on supervision, disclosure and enforcement.

Industry engagement has also increased. In December 2025, Blockchain Forum New Zealand (formerly BlockchainNZ) published A Roadmap for New Zealand’s Digital Assets Economy: 2025–2030 (the “NZ Strategy Paper”), advocating for a phased, internationally aligned regulatory framework. Expressly directed at parliament and regulatory agencies, it calls for co-ordinated legislative and regulatory action to clarify the legal treatment of digital assets (including classification, custody, exchanges and stablecoins) through a phased reform programme to 2030, aligned with international standards and aimed at reducing regulatory uncertainty while supporting responsible innovation.

Current Use Cases

Active use cases under consideration include the following.

• Tokenisation of assets – Following the FMA’s discussion paper on tokenisation in September 2025, firms are exploring blockchain-based representations of assets such as real estate, forestry, mining interests, carbon credits and precious metals. In March 2026, the FMA published a summary of the submissions received. The key themes included:
1. regulatory uncertainty is materially constraining adoption;
2. fragmentation increases consumer and systemic risk;
3. New Zealand risks falling behind comparable jurisdictions; and
4. industry broadly supports technology-neutral but clearer rules.
• Stablecoins and payments – Stablecoins have emerged as a practical payments and remittance use case. The FMA’s Financial Markets Conduct (ECDD Holdings Limited Stablecoin) Designation Notice 2026 (the “NZDD designation”) demonstrates how payment-focused stablecoins may be assessed under existing law. The NZDD designation declared that the NZDD stablecoin is not a financial product for the purposes of the Financial Markets Conduct Act 2013 (FMC Act). This was on the basis that the NZDD stablecoin is not an investment, pays no income or interest to holders, and is used practically as a means of payment or remittance. 
• Regulated investment exposure – Crypto-asset exposure is increasingly provided through conventional investment structures, such as managed funds and Exchange-Traded Funds (ETFs), reducing reliance on direct self-custody. For example, Raise Investments Limited’s Bitcoin ETF PIE Fund reports net fund assets of NZD26 million as of 31 March 2026, a significant increase from the NZD14.6 million under management in March 2024.
• Public sector exploration – The Reserve Bank of New Zealand (RBNZ) continues policy and design work on a potential central bank digital currency (CBDC) and monitors privately issued New Zealand dollar-backed stablecoins.

Key Issues Impacting the NZ Blockchain Market in the Next 12 Months

Key issues include:

• CARF implementation, increasing tax reporting, compliance obligations and costs for crypto-asset service providers;
• international regulatory pressure, driven by guidance from bodies such as the Financial Action Task Force (FATF), the International Organization of Securities Commissions (IOSCO), the Federation of Small Businesses (FSB) and the IMF, promoting licensing, AML/CFT compliance, consumer protection, custody standards and effective supervision;
• regulatory developments offshore, including new or pending digital asset regimes in Australia, the United States, the United Kingdom, the European Union, and many other countries (including notably in Asia, the Middle East and offshore finance centres), have passed regimes designed to both protect their consumers and attract innovative businesses to set up locally;
• whether New Zealand should introduce digital asset-specific regulation, including classification of digital assets, licensing of exchanges and custodians, and regulation of digital asset-related advice; and
• post-FTX (Futures Exchange) resilience measures, including increased oversight and application of Financial Market Infrastructure (FMI) Standards, particularly in relation to cyber-resilience and incident reporting.

Interaction With Intellectual Property Law

Blockchain businesses have generally operated within New Zealand’s existing intellectual property framework without fundamental difficulty. Copyright, trade mark, passing off and Fair Trading Act principles apply to non-fungible tokens (NFTs) and tokenised content in the usual way. Ownership of an NFT does not, without express agreement, transfer copyright in the underlying work.

Practical challenges arise where infringing content is minted or traded on immutable or decentralised platforms, as removal or modification may be difficult or impossible. Although New Zealand courts have not yet considered NFT-specific IP disputes, overseas decisions indicate that ordinary IP principles apply. Developers are therefore expected to address ownership, licensing, enforcement mechanisms and the use of Māori cultural material clearly at the design and launch stage.

In December 2024, the FMA announced a pilot regulatory sandbox for 2025, designed to allow firms to test innovative products, services and business models under regulatory supervision. The FMA welcomed the first group of participants in April 2025, and the pilot is now running but closed to new participants. The sandbox is not limited to blockchain projects, but it is relevant to blockchain-based products.

As of March 2026, the FMA identified that four of the firms involved in the sandbox pilot have identified a pathway to market for products or services that may have otherwise been delayed by regulatory uncertainty or other barriers.

The FMA asserts that the sandbox represents a significant development for New Zealand’s fintech and digital asset sector because it gives firms a supervised pathway to test innovative offerings while obtaining guidance on the application of existing financial markets regulation. For the FMA, the pilot provides practical insight into emerging business models, regulatory barriers, consumer risks and possible future regulatory responses.

The General Attitude of Government and Regulators to Blockchain-Based Industries

NZ has adopted a cautious approach towards regulating blockchain and crypto-assets. The FEC Report notes there are no legislative regimes in NZ directly targeted at digital assets. 

NZ continues to maintain a cautious, “wait and see” stance to regulation, but has begun engaging more actively with specific issues such as tokenisation, stablecoins, tax reporting and consumer protection.

Parliamentary Inquiry

The New Zealand Parliament – Pāremata Aotearoa Inquiry into the current and future nature, impact and risks of cryptocurrencies (the “Parliamentary Inquiry”) which commenced in 2021, and its related FEC Report and Government Response, are the first significant and co-ordinated legislative steps in developing NZ’s digital assets laws.

FEC Report

The FEC Report includes 22 recommendations for the government, emphasising a balanced regulatory approach. Key recommendations include creating a “Digital Assets Cross-Agency Working Group”, developing educational resources, establishing a regulatory sandbox for testing innovations, and ensuring consumer protection. The report advises against a single primary regulator due to the diverse uses of digital assets, and highlights the importance of flexible regulation that evolves with the industry.

Government Response

Although the FEC Report asked the government to consider all recommendations, the Government Response does not unfortunately address each one individually. Instead, it highlights ongoing work by various government entities that align with the FEC Report’s recommendations:

• the RBNZ’s exploration of the potential for a CBDC;
• the Council of Financial Regulators – Kaunihera Kaiwhakarite Ahumoni (CoFR) is providing guidance to start-ups through its Digital and Innovation Community;
• the Ministry of Justice (MOJ) is implementing recommendations for the AML/CFT treatment of virtual asset service providers;
• the FMA continues to offer guidance on digital assets and their treatment under the FMC Act, and takes regulatory action against breaches of financial markets law;
• the IRD provides guidance and information on the tax treatment of digital assets in NZ; and
• the Government Response concludes with a commitment to “continue to consider matters raised by the [FEC] and monitor international market developments”.

In relation to “regulation of digital assets” the Government Response notes that the FEC Report does not recommend adopting a fully integrated regulatory system, and instead suggests more consistent and informed guidance from government agencies on how existing legislation and regulatory rules apply in the digital asset space. It also recommends adding a defined class of digital assets which are used for investment purposes as a new category of “financial advice product”, to bring them into the regulated financial advice and client money/client property services regimes.

FMA Sandbox

See 1.1.2 Regulatory Sandbox.

CARF Implementation

See 1.1.1 Evolution of Uses of Blockchain. CARF has applied since 1 April 2026 and has introduced mandatory due diligence, data collection and reporting requirements for New Zealand-based Reporting Crypto-Asset Service Providers.

FMA Standard Conditions

The FMA has proposed updates to standard conditions for derivatives issuer licences, including new leverage limits and suitability assessments for retail investors, aiming to align with international practices and strengthen investor protection. New leverage limits and suitability assessments may impact cryptocurrency derivatives (eg, “perps”), as they are considered highly volatile. The MBIE has also announced a phased capital markets reform plan, with Phase 2 having commenced in 2025, to address aspects such as takeover laws and product disclosure requirements. Again, disclosure requirements could affect crypto-related financial products and services.

CoFI Regime

The Conduct of Financial Institutions (CoFI) regime took effect on 31 March 2025, introducing conduct licensing requirements and a “fair conduct principle” for financial institutions. This may shape how financial institutions handle crypto-assets. Furthermore, the RBNZ is implementing the Deposit Takers Act 2023, with consultations on prudential standards and the Depositor Compensation Scheme (DCS), which took effect on 1 July 2025. The DCS provides up to NZD100,000 of automatic protection in the event that a bank, credit union or finance company fails. However, financial information providers have indicated that traditional crypto-holdings are likely to fall outside this scheme because such asset purchases do not involve a deposit at a licensed deposit taker.

Digital Identity Services Trust Framework Regulations

The Digital Identity Services Trust Framework Regulations 2024 came into force on 24 October 2024. These regulations are part of the Digital Identity Services Trust Framework Act 2023, which provides a legal framework for secure and trusted digital identity services. The regulations establish accreditation requirements for digital identity services, including criteria for assessment, record-keeping, and reporting obligations. The framework aims to enhance trust and security in digital identity services. The regulations can impact on digital assets market participants in several ways:

• identity verification – digital asset platforms may need to comply with accreditation standards for verifying user identities, ensuring secure transactions;
• privacy and security – the framework enforces data protection rules, which could affect how digital asset providers handle customer information;
• compliance and trust – accredited identity services could be required for KYC and AML compliance, which is crucial in digital asset markets; and
• interoperability – the framework may encourage standardised identity solutions, making it easier for digital asset platforms to integrate with trusted identity providers.

FMA Outcomes-Focused Regulation (Update)

In March 2025 the FMA published an update regarding its approach to outcomes-focused regulation. This prioritises end results for consumers and markets over rigid compliance. Over the next few years, the FMA will refine its supervisory engagement, industry collaboration and sector insights to enhance transparency and fairness in financial services. The Financial Conduct Report, released in June 2025, was a major development which sets out the FMA’s regulatory priorities for the 2025/26 year and provides a more transparent view of conduct risks and supervisory priorities. This update is particularly relevant to blockchain and crypto-asset services, as the FMA has signalled increased scrutiny on the regulatory perimeter, which includes custody, funds administration, and wholesale financial products.

FMA’s Perimeter and Response Team

In 2025, the FMA introduced a dedicated team to assess activities at the edge of its regulatory scope, particularly concerning emerging technologies like blockchain. This team is responsible for determining whether certain activities fall within the FMA’s jurisdiction and deciding on appropriate regulatory responses, including potential enforcement actions.

NZ Strategy Paper

As noted in 1.1.1 Evolution of Uses of Blockchain, in December 2025, Blockchain Forum New Zealand’s Digital Asset Working Group published the NZ Strategy Paper, expressly directed at parliament and regulatory agencies. The paper records that the group brought together industry leaders, academics, legal experts, regulators and policymakers to develop a clear and practical framework for New Zealand’s digital-asset future. It notes that:

• nearly NZD8 billion is traded annually, almost half of New Zealanders have owned or considered owning digital assets, and the global blockchain industry is forecast to grow from USD33 billion in 2025 to nearly USD393 billion by 2030;
• 80% of New Zealand activity occurs on offshore platforms, taking talent, capital and innovation with it; and
• the opportunities are significant – new export industries, productivity gains, higher-value jobs, improved financial infrastructure and better consumer outcomes.

Smart contracts are capable of being enforced in New Zealand, provided they satisfy ordinary principles of contract law. There is no separate statutory regime governing smart contracts, and the New Zealand courts have not developed a bespoke test for their enforceability. Instead, the orthodox requirements for contract formation apply: there must be an offer, acceptance, consideration, intention to create legal relations, certainty of terms, and capacity. Where these elements are present, the fact that some or all contractual performance is automated through computer code should not, of itself, prevent enforcement.

The UK Jurisdiction Taskforce’s (UKJT) Legal Statement on Cryptoassets and Smart Contracts (the “Legal Statement”) was released in November 2019 with the aim of providing legal clarity on the status of crypto-assets and smart contracts under English private law.

The Legal Statement notes that:

• in principle, a smart contract can be identified, interpreted and enforced using ordinary and well-established legal principles;
• English law is already capable of managing anonymous or pseudonymous parties;
• English law is fully equipped to deal with bilateral smart contracts and also those structured around decentralised autonomous organisations (DAOs);
• requirements that a contract be signed can be met using a private key to authenticate the document; and
• requirements that a document be in writing can be met where a smart contract’s code element is recorded in source code (in many but not all cases).

The UKJT Legal Statement has been effectively endorsed by the courts in NZ. In Cryptopia, the court relied heavily on the Legal Statement in its analysis.

The MBIE Briefing Paper highlights the growing and developing use of blockchain as a key trend for NZ businesses. The MBIE also observes that NZ companies are already adopting smart contract technologies across various sectors such as supply chains, finance and the creative industries. While acknowledging the growing use of these technologies, the MBIE has not introduced specific regulatory frameworks for smart contracts but emphasises the need for quality governance as the technology evolves.

Smart contracts are also discussed in the FEC Report which noted in summary:

• while many smart contracts involve crypto-asset transfers, they can also be used in supply chains to securely record and share information among participants, similar to current Enterprise Resource Planning (ERP) systems. However, once recorded, the information is tamperproof and it can be made visible to other supply chain participants;
• however, the authors note that the term “smart contracts” is something of a misnomer;
• while some smart contracts can serve as legal agreements, many do not. For instance, blockchain voting systems use smart contracts to record votes but are not legal contracts; and
• for those smart contracts that are intended to form a legal contract (for now at least), such contracts tend to be straightforward.

Given the increased use of smart contracts and the ongoing development of blockchain, the law is having to adapt and evolve at pace. While NZ case law dealing with smart contracts is negligible, the NZ courts may take guidance from Australian decisions, including:

• Re Nasdaq Technology AB [2021] APO 39 – where Nasdaq filed a patent application involving smart contract technology, and the Deputy Commissioner of Patents found that the claimed invention was “not for a manner of manufacture”.
• ASIC v Web3 Ventures Pty Ltd [2024] FCA 64 (Block Earner) – where Australia’s regulator, the Australian Securities & Investments Commission (ASIC), sought declarations in relation to contraventions of the Corporations Act 2001 (the “Corporations Act”), that two of Block Earner’s products were “financial products”.
• ASIC v BPS Financial Pty Ltd [2024] FCA 457 (Qoin) – ASIC alleged that BPS carried on financial services business without holding an Australian Financial Services Licence (AFSL), and that it made false and misleading representations in connection with the supply or use of a financial product. The court found that the Qoin Wallet was a “financial product” for the purposes of the Corporations Act (specifically, a “non-cash payment facility”). However, the court rejected ASIC’s attempt to classify the entire Qoin blockchain that processed transactions as a “financial product” under Australian law. In this sense, the case could be seen as a precedent for how smart contract-enabled products should be legally assessed within Australia’s regulatory framework. 
• ASIC v BPS Financial Pty Ltd [2025] FCAFC 74 (Qoin) – on appeal from the 2024 Qoin decision, the Full Federal Court held that it was insufficient for BPS to have been appointed as an authorised representative of an AFSL holder. It found that BPS had developed, issued, promoted and operated the Qoin product in its own right. The court therefore declared that BPS had carried on a financial service without holding an AFSL.

Some of the services provided in these cases could be classified as a “financial service” under the Financial Service Providers (Registration and Dispute Resolution) Act 2008 (the “FSP Act”). The FSP Act defines financial services broadly to include services involving the transfer of money or value, such as payment services. These services would require registration and compliance with relevant regulations to ensure consumer protection and adherence to AML requirements (see 2.2 Crypto-Asset Regulatory Frameworks and 3.1 Licensing Requirements). Similarly, false statements about financial services would be covered by the fair dealing provisions of the FMC Act and/or the Fair Trading Act 1986 (FTA) (see 2.1 Regulators and International Alignment).

In summary, while there have been no significant legal or regulatory changes concerning the enforceability of smart contracts in New Zealand in the previous 12 months, the combination of regulatory initiatives, like the FMA’s sandbox and ongoing government monitoring, indicates a supportive environment for the continued integration of smart contracts into various sectors.

See 3.1 Licensing Requirements regarding FSP Dispute Resolution Schemes (DRSs) and 4.1 Marketing regarding New Zealand’s Advertising Standards Authority (ASA).

Blockchain Forum New Zealand (formerly BlockchainNZ) continues to serve as New Zealand’s primary industry group for the blockchain and digital asset sector.  Operating under the NZTech umbrella, Blockchain Forum plays a pivotal role in policy advocacy, industry co-ordination and community engagement. Additionally, as noted in 1.1.1 Evolution of Uses of Blockchain and 1.1.3 Regulation of Blockchain Technology, the organisation is actively engaged in regulatory discussions through its Digital Assets Working Group, contributing to policy dialogues and consultations.

In August 2025, BlockchainNZ (as it then was) hosted CryptoWinter’25, an inaugural blockchain and crypto conference across two days in Queenstown, New Zealand. The event involved keynote speakers, blockchain discussions and interested parties from across the industry, academic sphere and government representatives. The success of CryptoWinter’25 has led to it coming back to Queenstown this August for CryptoWinter’26. In December 2025, BlockchainNZ hosted the annual Blockchain Awards, celebrating notable contributions within Aotearoa’s blockchain and Web3 industries.

New Zealand’s Approach to Crypto-Assets and the Transfer of Crypto-Assets

In New Zealand, the ownership and transfer of digital assets are governed by traditional common law and equitable property principles adapted to digital assets and blockchain technology.

The landmark case of Ruscoe v Cryptopia Ltd (In Liq) [2020] NZHC 728 established that cryptocurrencies are intangible personal property capable of being held on trust. The High Court held that control over a digital asset – linked to possession of the private cryptographic key – is the key element of property ownership, analogous to possession under common law. In March 2024, the High Court approved the liquidators’ distribution methodology, recognising that changes in beneficial ownership recorded only on internal ledgers (and not on-chain) still constituted valid transfers under trust law.

Regarding finality, blockchain transfers are considered final when confirmed on-chain and the recipient gains control through their private key. Where intermediaries (eg, exchanges or custodians) are involved, traditional equitable principles apply – the intermediary may hold assets on trust, and equitable remedies such as tracing remain available if assets are misappropriated, provided the recipient’s public address can be identified.

Issues Relating to the Use of Digital Assets in Collateral Arrangements

There do not appear to be any specific legal or regulatory issues precluding the use of digital assets in collateral arrangements in New Zealand. Property-related statutes such as the Personal Property Securities Act 1999 (PPSA) and its related registration regime may apply.

There have been no legislative or regulatory changes in the last 12 months specifically addressing digital assets in collateral arrangements. Neither the FMA nor the MBIE has issued guidance on the application of the PPSA to digital assets, and practical issues of perfection, control and enforcement in decentralised or self-custodied environments remain unresolved. Commercial interest in crypto-backed lending has nonetheless grown, with fintech platforms piloting crypto-collateralised loan products. In the absence of formal regulation or case law, practitioners are relying on private legal opinions to structure these arrangements.

Restrictions on Crypto-Asset Services Accessing Banking and Payment Partners or Services

While there are no specific legal restrictions in New Zealand preventing firms that provide crypto-asset services from using ordinary banking or payment partners, a study published by Web3NZ and supported by BlockchainNZ (now Blockchain Forum New Zealand) suggests that digital asset-related businesses do experience challenges with banks. The study stated that 56.8% of surveyed Web3 businesses in New Zealand reported challenges in maintaining local banking access, and noted that 82.4% of respondents are either already relocating their business offshore to address regulatory constraints and banking service issues, or will do so in the future if nothing changes. This suggests that should there be no reform in local practices, crypto-asset businesses are likely to be lost overseas.

There are currently no “crypto-specific” ESG/sustainable finance requirements applicable to crypto-assets in NZ. However, one of the terms of reference for the Parliamentary Inquiry was “to understand the environmental impact of ‘mining’ cryptocurrencies” and this issue is addressed in detail in the FEC Report.

NZ’s approach to crypto-assets taxation has to date – according to the FEC Report – been “ad hoc and belated” with “sporadic amendments to the Tax Acts as they come”. The FEC Report recommended that the IRD should explore whether tax incentives for crypto-assets service providers are necessary or appropriate, in addition to continuing work to provide clarity around the treatment of crypto-assets in terms of tax and to encourage investment of capital in NZ, as well as enhance the competitivenesul s of the NZ tax system.

The most significant legislative change to date has been with the Taxation (Annual Rates for 2021–22, GST, and Remedial Matters) Act 2022, which affirmed that crypto-assets are not subject to GST, and are generally “excepted financial arrangements”. NZ, like many countries, faces challenges in the classification of different crypto-assets within its existing tax system.

The IRD has issued helpful guidance on the taxation of crypto-assets. It notes, among other things, that crypto-assets are treated as a form of property for tax purposes. The IRD guidance includes a number of “tax technical” issues papers and rulings covering a range of topics.

Implementation of the OECD’s CARF

As discussed in 1.1.1 Evolution of Uses of Blockchain and 1.1.3 Regulation of Blockchain Technology, on 1 April 2026, New Zealand adopted CARF. This framework mandates crypto-asset service providers to collect and report user transaction data to the IRD, enhancing transparency and aligning with international tax standards.

Inland Revenue’s Enforcement Actions

In April 2026, the IRD stated that it had identified 355,000 unique crypto-asset users conducting approximately 57 million transactions totalling NZD36 billion. The IRD will be matching information obtained through CARF with tax returns and identifying discrepancies. Letters have been sent to individuals the IRD believes have underreported their crypto-asset earnings.

There are currently no specific resolution or insolvency requirements/regimes for crypto-asset firms in NZ. The existing legal framework continues to apply, with general insolvency procedures under the Companies Act 1993 (the “CA93”) and related legislation governing such matters.

Case law and related commentary regarding Cryptopia is likely to assist insolvency practitioners and claimants in other NZ crypto-asset related insolvencies. Similarly, NZ market participants may receive guidance from overseas insolvencies.

Insolvency Procedural Options

• Liquidation: While each insolvency situation will turn on its own facts, liquidation under the CA93 (or Limited Partnerships Act 2008) may be well suited to insolvent exchanges or custodians that also act as trustees on behalf of account holders. Liquidators are subject to the supervisory jurisdiction of the High Court, and liquidations do not face the same tight time constraints as voluntary administrations. Liquidators have the authority to recover, protect, preserve, and administer trust assets, and there is considerable case law guidance on this.
• Voluntary administration (VA): In contrast, VA is primarily designed to address the interests of creditors. Although Part 15A of the CA93 refers to the interests of both creditors and shareholders, the courts have clarified that shareholders’ interests are secondary. VA may therefore be unsuitable for dealing with assets held on trust, and the tight timing requirements (even with court-ordered extensions) make it challenging to resolve questions about whether assets are held in trust in a timely manner. However, a successful deed of company arrangement (DOCA) was reached in relation to the VA of Australian company, Digital Surge, which collapsed following FTX.
• Schemes of arrangement under Part 15 CA93 may not be available for the distribution of trust assets because Part 15 requires that the arrangement be between a company and its creditors or shareholders. Under Part 15, a creditor is defined as being a creditor entitled to prove in a liquidation, as per Section 240 of the CA93. Trust beneficiaries are typically not considered creditors.
• Receivership: A receiver’s primary duty is to secure repayment of monies owing to their appointor, not to administer trusts. The receivership and VA of Futureverse in September 2025 highlights how both options may run in tandem.

See the discussion in 3.1 Licensing Requirements regarding FSP DRSs and in 4.1 Marketing regarding the ASA.

Also, see the discussion in 1.1.5 Industry and Trade Bodies regarding Blockchain Forum New Zealand and its role in the crypto-asset industry.

New Zealand’s regulatory framework does not distinguish between fiat-backed stablecoins and algorithmic stablecoins. There is no dedicated stablecoin legislation, and the classification of any stablecoin depends on its specific features and functions – assessed on a case-by-case basis by the relevant regulator – rather than on its label or the mechanism by which it maintains its peg.

There is no bespoke regulatory framework for stablecoins in New Zealand. Currently, the FMA assesses each stablecoin on a case-by-case basis based on its features and functions. The key considerations for whether a stablecoin is a financial product are discussed in 2. Regulation.

In October 2025, the FMA designated the NZDD as not being a financial product under the FMC Act, on the basis that it is not an investment, pays no income or interest to holders, and is used practically as a means of payment or remittance. This designation is product-specific but signals how the FMA may approach similar stablecoin models.

See 6.1 Payments and 6.2.2 Stablecoin Regulation.

See 6.2.2 Stablecoin Regulation.