ComCom begins shaping expectations for infrastructure reslience investment
With risks to infrastructure increasing and the consequences of service disruptions becoming more significant, the Commerce Commission has begun shaping how infrastructure resilience investment could be undertaken more effectively in New Zealand.
Today it’s released draft cross-sector guidance aimed at ensuring investment in infrastructure resilience is carefully considered, reflects the costs faced by consumers, and strengthens the ability of essential services to withstand and respond to increasing risks.
Associate Commissioner Nathan Strong says with the growing pressure on New Zealand’s infrastructure, a deliberate and consistent approach to infrastructure resilience investment is needed.
“Services like electricity, water, and telecommunications are often taken for granted, but their loss during extreme events can be severely disruptive. And with increasing frequency and severity expected, short-term or ad hoc responses won’t deliver reliable, efficient services over time.
“We know that in some cases, more resilience investment will be needed. But it’s critical that these decisions are made in a structured and transparent way, with a strong understanding of the risks being managed and the benefits delivered.”
Strong says investment decisions need to reflect what matters most to communities.
“Consumers ultimately pay for these investments, so it’s important that decisions are grounded in engagement on current service resilience and preparedness, as well as options for improvement. Investment decisions should also reflect communities’ tolerance for risk and the value of more resilient services.”
The draft Resilience Principles: Decision-making framework for critical infrastructure providers sets out 11 key resilience principles, supported by examples, and the Commissions high‑level expectations of the types of approaches infrastructure providers should take when assessing resilience investments, alongside examples of what good looks like.
It also outlines the Commissions expectation that use of these approaches should improve and become more advanced over time.
“Ultimately we want to see providers carefully assessing the balance between cost, risk and service levels while recognising it will not be efficient to mitigate every risk.”
The Commission is also encouraging board members, senior governance bodies, and executive leaders to take an active role in understanding and overseeing resilience investment.
“Leaders need to be confident they understand the risks their organisations face, the trade-offs being made, and whether investment decisions are delivering long-term outcomes for New Zealanders.
“Good investment in resilience isn’t just about building stronger assets. It’s about how systems perform under stress – how quickly they can respond, recover, and continue delivering essential services.”
Better coordination across infrastructure providers will also help improve outcomes for consumers.
The proposed principles are most directly relevant to providers that are subject to price quality regulation, given that they would engage with the Commission for approval to recover investment costs from consumers. The guidance does however not create new requirements for infrastructure providers.
The Commission is seeking feedback on the draft guidance until 31 July 2026.
For more information, see our Resilience principles for investment decision-making page.