(Government Bill 132—1, Judith Collins)
From: Ukes Baha | 17 April 2025
Submitted in response to the call for public submissions on the Plain Language Act Repeal Bill (Government Bill 132—1)
I oppose the Plain Language Act Repeal Bill (Government Bill 132–1) on the grounds that it is unnecessary, harmful to public accessibility, and inconsistent with democratic and Tiriti obligations. The Bill seeks to repeal the Plain Language Act 2022 without offering an alternative framework or evidentiary justification. The proposed repeal is inconsistent with good public administration, democratic participation, and the principles of Te Tiriti o Waitangi. It undermines existing investment in institutional reform and erodes accessibility for all members of the public, particularly those who are most reliant on clear and inclusive government communication.
The Plain Language Act 2022 (Public Act 2022 No 54) was enacted to improve the effectiveness, accountability, and accessibility of public service agencies and Crown agents by requiring the use of plain language in key public-facing documents. The definition of plain language under section 5 of the Act is uncontroversial: communication that is “appropriate to the intended audience” and “clear, concise, and well organised.”
The Act applies only to documents intended for the general public, such as guides on government services, compliance requirements, and public education materials (section 6). It imposes no judicially enforceable rights, but rather internal standards, non-binding guidance, and procedural reporting obligations to promote cultural and operational change across the public sector.
The explanatory note accompanying the Repeal Bill alleges that the Plain Language Act imposes compliance-based costs without producing meaningful improvement. However, no empirical evidence has been presented to substantiate this claim. The Act imposes only modest obligations: the appointment of plain language officers (section 11), annual internal reporting (section 12), and adherence to non-enforceable guidance issued by the Public Service Commissioner (section 10). These are entirely consistent with standard public management practices.
Since the enactment of the Act, agencies have taken steps to educate staff, revise communication processes, and embed plain language practices into service design. This includes investment in training, interdepartmental guidance, and structural change. The repeal would effectively discard this progress, undermine staff morale, and signal that long-term public service improvement is reversible and expendable. It would also represent a waste of public funds and strategic alignment already committed to implementation.
The Plain Language Act serves as a critical tool for ensuring that government information is accessible to all, including:
The repeal removes the only explicit legislative commitment, disproportionately affecting those least able to advocate for themselves and thereby exacerbating structural inequality.
While the Plain Language Act 2022 does not contain explicit references to Te Tiriti o Waitangi, its provisions are clearly aligned with the principles of partnership, active protection, and equity. By promoting the accessibility of public information, it strengthens the Crown’s ability to engage with whānau, hapū, and iwi in a meaningful and participatory manner.
Moreover, plain language is fundamental to democratic governance. Every member of the public—regardless of background—has the right to understand the laws, services, and rights that govern them. This includes:
Repealing this legislation risks reintroducing barriers to participation, eroding trust in public institutions, and undermining both Treaty obligations and fundamental democratic values. When government communication becomes less accessible, the public becomes less empowered—and that is contrary to the very principles of open, inclusive governance in a free society.
Many jurisdictions—including the United States (via the Plain Writing Act of 2010), Canada (with its Clear Writing and Design standards), and several EU member states—have implemented and sustained legislative frameworks promoting plain language. These efforts are part of a broader global movement to modernise public service delivery and strengthen democratic engagement through clear and accessible communication.
Repealing New Zealand’s Plain Language Act would set the country apart as a regressive outlier, undermining its reputation as a leader in transparent, citizen-focused governance.
It is respectfully submitted that the Committee should:
The Plain Language Act 2022 affirms the principle that public communication must serve the people—not the bureaucracy. It enables participation, protects equity, and promotes efficient governance. Its repeal is unwarranted, unprincipled, and likely to result in long-term harm to public service capability and civic trust.
Accordingly, this submission opposes the Plain Language Act Repeal Bill and urges the Committee to recommend that it not proceed.
Ukes Baha
Public Health Advocate | Counsellor | Policy Analyst
ukesbaha.com