Our submission commends the Reserve Bank of New Zealand (RBNZ) for its efforts in responding to feedback received from stakeholders, such as the External Reporting Board (XRB) and auditors, and attempting to resolve the challenges identified. In our view the changes proposed in this consultation are a good starting point toward addressing some of those challenges. 

We support clarifying the scope of the assurance engagements, in particular which parts of the disclosure statement are to be subject to which level of assurance, aligning the terminology used to describe this with that used in the NZAuASB standards, and removing duplication of the requirements in the NZAuASB standards.

While we agree the changes being proposed are a significant step forward, we make a number of recommendations that would further improve the drafting of the Orders in Council.