Early childhood education

Mātauranga Kōhungahunga

We have made the following submissions the government entities on issues relating to early childhood education. To view the submissions, click on the titles below. 


Education and Training Act Amendment No 3

We agree that the Ministry of Education should be able to access ECE data from Statistics NZ to develop a new Equity Index that is based on accurate socio-economic information. We are satisfied that any data accessed will not include personal information unless the individual has consented to the publication or disclosure.

We strongly agree that employers need to assess police vets for non-teaching employees and contractors. It is crucial that all people working with or having unsupervised access to tamariki at ECE services and schools are not only police vetted but that the results of that vet is assessed for any risks to the safety of children is made

Amendments to ECE Regulations to accommodate Crown acquisition of land and network approval

We believe this is a sensible change that will make it easier for ECE centres that find themselves in the position of needing to relocate due to no fault of their own.

Adding conditions to provisional licences, defining 'permanently ceased to operate' and providing for temporary closures

We support the proposed change to the regulations that will allow the Ministry to respond appropriately and in a timely manner if additional compliance issues are identified. We also agree that where a provisional licence is near the end of the 12 month period and new conditions are found that the Secretary can wait until the current provisional licence period ends and then issue a new provisional licence.

We agree that there is a need for temporary service closures and that the regulations should be amended to formalise the definition of and process of voluntary temporary closures. This will remove any impression that these types of closures are occurring outside the legislation.

Providing a definition of 'locally based' for PR in home-based

We agree that the regulations are amended to include a definition of ‘locally-based’ for persons responsible for licensed home-based education and care services. This will remove the current ambiguity for providers, especially those with homes in more rural / remote locations.



Gazetting Te Whāriki

We agree that ECE services and certificated play groups should be required to implements the goals and learning outcomes of Te Whāriki. Gazzetting Te Whāriki would creat clear expectations that every child experiences a rich and empowering curriculum and would support formative assessment. Services will need guidance and exemplars as well as clear expectations from ERO in what they are looking for in terms of evidence of meeting curriculum requirements.

As a bicultural organisation, we agree with including a te ao Māori interpretation of the goals and learning outcomes.

Network Management: Priorities of National and Regional Statements and new regulations

We agree with the proposed priorities and are pleased to see Pacific cultural services as well as bilingual services and immersion services included. We note that services with specific philosophies are not on the priority list.. In termas of the regulation, we are happy with what has been proposed..

Fair Pay Agreements Bill

While we are generally in support of Fair Pay Agreements which have the potential to raise and standardise the employment conditions across industries or occupations, we have a number of queries and concerns regarding the proposed Bill and its impact on the Early Childhood Education (ECE) sector.

Supplementary Order Paper to Education and Training Amendment Bill (No 2)

The SOP introduces the new Network management functions that were consulted on in November 2021


Tranche Two of the Early Learning Regulatory Review - strengthening PR requirements for home-based services (13 October 2021)

We agree that the role of person responsible in home-based services needs both strengthening and made more overt. The way the current Regulations have been interpreted has led to a lack of accountability by some home-based providers.

Tranche Two of the Early Learning Regulatory Review - implementing new network management functions (13 October 2021)

Overall, we support a sound managed network that is in the best interests of providing early childhood education to tamariki, their whānau and communities. Having a streamlined but considered due diligence case when entering as a service or expanding existing services will provide quality in decision making and ECE provision.

Tranche Two of the Early Learning Regulatory Review - 80% qualified and persons responsible (13 October 2021)

We believe that Option 3 (ensuring ECE qualified and certificated teachers are always present) is the best option for quality but are concerned about how services are going to reach and maintain this level until we have a workforce that is well-balanced between supply and demand.

Tranche Two of the Early Learning Regulatory Review - regulations for home-based educator qualifications (27 September 2021)

While e agree with the proposed changes to the regulations, we question how some will be implemented and monitored.

Education and Training Amendment Bill (No 2) (16 June 2021)

Our submission concerns the following five areas of the Education and Training Amendment Bill:

  • Proposed changes for Police vetting of non-teaching and unregistered employees
  • Proposed changes to strengthen Teaching Council processes
  • Proposed changes to how compulsory student services fees are regulated
  • Proposed changes to NZQA cancellation of PTE registration for immigration breaches
  • Proposed changes to amend the Education Review Office’s mandate

Education and Training (Grants - Budgets Measures) Amendment Bill (4 June 2021)

While we support the intended outcome of this bill, that is to provide early childhood teachers parity with kindergarten teachers now and always in the future, we are concerned with the wording of the Bill and the financial risks this presents to education and care services.  

Establishing an ESA (Education Service Agency) within a redesigned Ministry of Education (31 March 2021)

The proposed ESA includes three Regional Delivery Groups, an Operations & Integration Group, Te Marautanga (the Curriculum Centre) and an Infrastructure & Digital Group. These will sit within the wider MOE containing the Māori Education Group, the Policy & Integration Group, the Corporate Group and the Office of the Secretary.  


Early Learning Regulatory Review - Tranche 1 (10 February 2021)

The Early Learning regulatory Review is being carried out in 3 tranches. Tranche 1 covers a number of areas relating to licensing of services.


Learning Support Coordinator - Guide to the Role (8 April 2020)

The draft guide clarifies questions people may have about what LSCs are and what they do. The document will be useful not just for LSCs but also for the wider community. and parents and whānau of the tamariki they are supporting. You can read our submission here.

Education and Training Bill (10 February 2020)

We agree with the structure change of the proposed Bill.  We provided feedback on a number areas that will impact on the ECE sector including Home-based changes;  licensing practices; police vet processes; expansion of ERO powers; and the return to teaching pathway. We also commented on the functions of workforce development councils. You can read our submission here.

The Education and Training Act came into effect on 1 August 2020. You can view the Act here.


National Party Education Discussion Document (7 December 2019)

Our feedback was in the form of an online survey.

ERO Indicators of quality for early childhood education (30 November 2019)

We like that the outcome indicators are open ended and linked to Te Whāriki and focussed on children’s learning.  We are pleased to see entire indicators for leadership and the emphasis on stewardship through effective governance. We are also pleased there is provision for professional development under both ‘Evaluation for Improvement’ and ‘Leadership’. View our survey response here.

ERO have released their new indicators of quality, Te Ara Poutama which are available here.

First Aid Qualifications (28 November 2019)

We agree with the proposed simplification of first aid qualifications. The proposed areas to be taught include what is in the current qualifications.  We are pleased that the qualification covers both CPR and choking for children and infants. Our submission was in the form of an online survey.

Statement of National Education and Learning Priorities (NELP) (25 November 2019)

The proposed priorities send a strong signal to the early learning sector on what is expected in terms of working with tamariki and their whānau to have a positive impact for children. It is good to see a balance between the needs of children, their whānau, as well as the teachers and leaders of early learning services.  We are pleased to see that all of the priorities are well aligned with Te Whāriki and the inclusion of family and whānau in the life of services is consistent with the requirements of the licensing criteria. 

The NELP have now been finalised and gazetted. You can read about the NELP here.

Person responsible requirements in ECE centres (18 October 2019)

We are concerned that if this change is made – even as a temporary measure until the full Early Learning Strategic Plan is implemented through additional changes to the regulations, what other allowances might the government make? What is needed is a programme to increase the number of qualified ECE teachers through attraction to the profession, by supporting those already in the sector to gain a qualification, and incentives in place for others to become qualified.

View the Government’s decisions on the review here.

Pacific Education Fono (10 October 2019)

We believe that it is important that Pasifika Education Plan (PEP) places more emphasis on supplying teachers who have some understanding of Pasifika cultures and ways of children’s knowing and being. The PEP must also re-emphasise the long-standing importance of teachers working in partnerships with families to strengthen children’s educational experiences.

View the Government’s Action Plan for Pacific Education 2020-2030 here.

Tomorrow's Schools Review (4 April 2019)

The Taskforce’s recommendations largely ignore the need for a fully integrated education system. What happens in early childhood education makes a difference for a child’s learning journey and life outcomes, so it is vital that early childhood education be included in overarching system design.

View the Government’s decisions on the review here.

Strategic Plan for Early Learning (15 March 2019)

We support many of the recommendations in the strategic plan, especially those that address issues the early learning sector has been asking the government to invest in for nearly a decade. The recommendations we think should be prioritised include:  Improved qualified teacher targets, ratios and group size; Teaching workforce salary and conditions; Teacher Education – initial and ongoing professional learning and development. The final plan is called the Early Learning Action Plan.

View the Government’s decisions on the review here.