Submissions

To: Governance and Administration Committee
Date: May 2025

Purpose

This submission/s primary purpose is to strongly oppose the repeal of the Plain Language Act 2022, arguing that its repeal would undermine government effectiveness, accountability, and, critically, the human rights of disabled people to access clear, understandable information. DPA aims to highlight the Act's significant benefits for communities, particularly those facing communication barriers, and emphasizes that its repeal would be a regressive step.

Summary of DPA submission

DPA urges the withdrawal of the Plain Language Act Repeal Bill. DPA emphasises that one of the original purposes of the Plain Language Act 2022 was to improve government effectiveness and accountability, which are crucial in a democracy, as clear communication enables the public to better understand government actions and decisions.

DPA highlights that using plain language specifically benefits people who need to process information quickly, those with English as a second language, and individuals with low literacy levels. Critically, communities most impacted by government decisions, including disabled people, are among those who benefit most from clear information. Many disabled people encounter significant barriers to accessing communications in easily understandable formats; this includes people with learning disabilities and neurodiverse/autistic individuals who have reading difficulties, D/deaf people who use New Zealand Sign Language (NZSL) as their first language and may have low literacy, and blind and low vision people who struggle with written materials.

DPA argues that plain language makes the translation of documents and communications into accessible formats like NZSL and Easy Read significantly easier. The submission cites Statistics New Zealand data indicating that 27% of disabled people leave school with no qualifications (compared to 13% of non-disabled people) and national literacy data showing that around 48% of adults have low literacy skills. DPA notes that disability service providers and Disabled People's Organisations previously supported the plain language law in 2022. DPA refutes the argument that repealing the law would save money, pointing out that plain language officers are existing staff and that clearer communication actually saves the government millions in follow-up inquiries and explanations for unclear information.

DPA believes the government did not allow sufficient time for the Act to demonstrate its full benefits and, furthermore, failed to consult with disabled people and other impacted communities before proposing its repeal. DPA asserts that repealing the Plain Language Act would represent a "huge step backwards" in recognizing the human rights of all people, including disabled people, to receive accessible information. Consequently, DPA firmly believes that the repeal would put the New Zealand Government in breach of Article 21 of the UNCRPD, which specifically upholds the right of disabled people to receive information in accessible formats, including plain language.

Key Recommendation/Finding:

DPA believes that if this Act is repealed that the New Zealand Government will be in breach of Article 21 of the UNCRPD, which upholds the right of disabled people to receive information in accessible formats, including plain language.

Supporting Statement 1:

Many disabled people, including those with learning disabilities, D/deaf individuals (whose first language is NZSL and may have low literacy), and blind/low vision people, face significant barriers to accessing communications in easily understandable formats.

Supporting Statement 2:

Plain language significantly simplifies the process of translating government documents and communications into crucial accessible formats like NZ Sign Language and Easy Read, which are essential for effective information dissemination to disabled communities.

To: Governance and Administration Committee
Date: May 2025

Purpose

The Plain Language Act Repeal Bill looks to repeal the Plain Language Act 2022 to remove the compliance-based administrative requirements the Act places on public service agencies.

Summary of DPA submission

We ask that the Bill be withdrawn.

One of the purposes of the Plain Language Act 2022 is to improve the effectiveness and accountability of government. Accountability is important in a democracy. Repealing of this Act will affect ordinary people’s rights to hold their government accountable and understand the impact of its decisions, including when they affect ordinary people.

Clear communication enables the public to better understand the government’s actions and decisions.

At the individual level, using plain language benefits:

• people who need to take in a lot of information quickly
• people who have English as a second language
• people with low literacy levels.

Communities that benefit most from clear information are often those that are most impacted by government decisions - this includes disabled people.

DPA wants to see the rights of disabled people to access good, clear information from government upheld.

Many disabled people face barriers to accessing communications in formats and ways that can be easily understood, and this includes:

• people with learning disabilities and neurodiverse/autistic people who experience difficulties in reading material
• D/deaf people who have New Zealand Sign Language (NZSL) as their first language and experience low literacy; and
• blind and low vision people who often receive letters or sign forms they cannot see or sign.

When documents and communications are in plain language then it makes their translation into accessible formats including NZ Sign Language and Easy Read much easier to do.