How the Reserve Bank’s BS11 outsourcing policy and the FMA’s conduct expectations shape banks’ and financial firms’ use of AI and cloud in New Zealand.

dgm is an independent osFoundry integration partner — not affiliated with the company that makes osFoundry, and dgm has not yet completed any client integrations. This article describes services dgm offers, not past results.

In New Zealand financial services, AI is shaped not by an AI law but by the Reserve Bank’s outsourcing rules and the FMA’s conduct expectations.

Key points

  • The RBNZ’s BS11 outsourcing policy (Sept 2022) covers cloud/outsourcing for the largest banks
  • The FMA published AI-in-financial-services research in July 2024
  • The FMA expects a proportionate, risk-based approach relying on existing law
  • Vendors serving NZ banks should expect BS11-driven control and separation requirements

The detail

In 2026 New Zealand has no standalone, binding AI law — and, because New Zealand is not in the EU, the EU AI Act does not apply here either. The government’s approach is deliberately light-touch and risk-based, relying on existing law. The public-sector touchstone is the Algorithm Charter for Aotearoa New Zealand, a voluntary commitment launched in July 2020 and signed by more than 25 government agencies. In July 2025 the government released New Zealand’s first national AI strategy, ‘Investing with Confidence’ (led by MBIE, built on the OECD AI principles), together with voluntary Responsible AI Guidance for Businesses and a non-binding Public Service AI Framework (GCDO / Department of Internal Affairs). None of these is a binding Act. What actually binds an organisation using AI is the Privacy Act 2020 plus the rules of whichever sector regulator applies — not an ‘AI Act’. Check the latest guidance, because this area is moving quickly.

Where this leaves your AI project

A model-agnostic platform like osFoundry helps you meet these obligations in practice — you can keep data in New Zealand (an Auckland region or local-first), control model choice via BYOK, and connect to your own systems. dgm can help you scope and implement with this in mind.

How dgm can help

dgm is an independent integration partner that helps New Zealand organisations put osFoundry to work — from choosing a worthwhile first use case through to the hands-on build and connecting it to the systems you already run. dgm is not affiliated with the company that makes osFoundry, and it has not yet completed any client integrations, so what is described here is the service dgm offers, not past results. If you want help scoping a realistic first project, dgm can work through it with you.

This article is general information only and is not legal, tax or investment advice. Rates, caps and programme status change — confirm the current position with the relevant official body or a licensed adviser before you act.