Further to Reply 17207 (2026), at the time the 16 April 2025 amendment to the CoP control was approved, were the decision-makers aware that CoPs could be, or were being, forged; if so, what was the basis for the proportionality assessment; and what consideration was given to the effect a forged CoP would have on the control's operation across risk classifications?

Answer

I am advised by NZTA that decision-makers were aware, in general terms, that fraud risk exists within the driver licensing system, including that Certificates of Particulars (CoPs) have historically been a potential entry point for fraudulent activity. However, decision-makers were not aware that fraudulent or falsified CoPs were being actively submitted as part of applications at the time, nor that this issue had reached a level of operational significance. The specific risk relating to fraudulent CoPs was not identified as being a current material issue until after 16 April 2025. On that basis, no additional weighting was applied to the risk of forged CoPs in determining the appropriate control settings. As noted in my reply to 18705 (2026), the amendment to the CoP control did not affect the fraud in question, as applicants were required to submit a CoP both before and after 16 April 2025.