Formal Opposition to
Immigration (Fiscal Sustainability and System Integrity) Amendment Bill

(Government Bill 138–1, Erica Stanford)

From: Ukes Baha | 27 July 2025

Submitted in response to the call for public submissions on the Immigration (Fiscal Sustainability and System Integrity) Amendment Bill


Summary of Position

I oppose the Immigration (Fiscal Sustainability and System Integrity) Amendment Bill in full.

Despite its bureaucratic title, this bill delivers neither fiscal sustainability nor integrity. It instead centralises unchecked executive power, normalises electronic surveillance, expands arbitrary classification, and monetises migrants to underwrite public services.

It undermines rights, weakens due process, and reshapes immigration into a tool of social control and fiscal extraction — not a fair or humane gateway to residence, safety, or belonging.


1. Expands Ministerial Discretion Without Boundaries

The bill grants the Minister sweeping powers to:

Problem: These powers bypass democratic oversight. They turn legal process into political discretion and allow systemic favouritism, profiling, and abuse without legal consequence.


2. Legalises Surveillance of Migrants Through Electronic Monitoring

Sections 324F and 324J introduce body-worn tracking devices for migrants under conditional release. These include GPS-enabled surveillance and enforcement powers based on collected data.

Problem: This is invasive, dehumanising, and out of step with rights-based law. Migrants under no criminal charge can be digitally tagged and monitored like prisoners — a dangerous precedent for administrative detention.


3. Redirects Immigration Levies to Fund Unrelated Services

The bill allows the extended immigration levy to fund education, health infrastructure, and employer training cost offsets.

Problem: This is state cost-shifting onto migrants and employers, turning immigration into a budget band-aid. Public services should be funded by general taxation — not by exploiting newcomers who have limited access to those services.


4. Enables Broad Profiling Based on Nationality or Visa Type

The bill authorises special visa rules, waivers, conditions, and extensions to be applied to entire classes of people based on:

Problem: This legalises discrimination in practice. Migrants can be treated unequally not for what they’ve done — but for where they’re from. It violates principles of natural justice and undermines social cohesion.


5. Undermines Refugee and Humanitarian Protections

New powers enable:

Problem: This strips refugees of durable status while offering no fair recourse. It contradicts New Zealand’s international commitments and entrenches permanent precarity.


6. Authorises Intrusive Searches of Homes and Marae

Immigration officers may now apply for out-of-hours search warrants targeting dwellings and marae — with limited cultural safeguards.

Problem: This violates the sanctity of both home and marae. Even with procedural steps, it normalises paramilitary-style enforcement and disrespects tangata whenua authority and tikanga.


7. Disrespects Te Tiriti o Waitangi

Nowhere in the bill is there mention of:

Problem: The Crown continues to legislate with colonial assumptions, erasing Māori partnership while extending state power over indigenous spaces.


8. Removes Guardrails from Key Decisions

Across the bill, powers are introduced or expanded with:

Problem: This is a blueprint for executive overreach. It turns temporary “flexibility” into permanent loopholes and weakens the rule of law.


9. Reframes Immigration as Risk, Not Contribution

The bill portrays migrants as:

Problem: It feeds anti-migrant narratives and ignores the value, humanity, and aspirations of those seeking life in Aotearoa. It is a bureaucratic betrayal of compassion and justice.


Conclusion and Recommendations

This bill does not uphold integrity — it consolidates unchecked control. It opens dangerous legislative pathways and undermines trust in the immigration system.

I recommend the Select Committee:

  1. Reject the bill in full
  2. Repeal any extensions to ministerial powers not subject to legal oversight
  3. Remove electronic monitoring provisions from immigration law entirely
  4. Prevent immigration levies from funding unrelated public infrastructure
  5. Prohibit classification by nationality or visa class
  6. Ensure full compliance with Te Tiriti o Waitangi, especially in relation to marae and community sovereignty
  7. Establish transparent appeal and review mechanisms for any new detention, surveillance, or visa decision-making powers
  8. Protect refugee status pathways from cancellation or indefinite limbo

An immigration system must serve fairness, not fear. And no Minister should be above the law.


Respectfully submitted,
Ukes Baha
Public Health Advocate | Counsellor | Policy Analyst
ukesbaha.com