Submission on MBIE Capital Markets Reforms: Phase Two

Supporting capital market reform that recognises different ownership models.

Cooperative Business NZ has submitted feedback to MBIE on its Capital Markets Reforms: Phase Two consultation.

Our submission supports the overall direction of the reforms, particularly the focus on proportionality, reducing unnecessary compliance costs and ensuring businesses have appropriate options for raising capital.

We have taken a deliberately high-level approach, focusing on an area we believe is currently under-recognised: how New Zealand's capital markets framework accommodates cooperatives, mutuals and other member-owned businesses.

Submission at a glance

• Submitted by: Cooperative Business NZ 

• Date: august 2026 

• Submitted to: mbie

• Policy area: CAPital markets and member ownership

• Format: written submission (PDF) 

CBNZ position

Cooperatives and mutuals can have capital structures and capital requirements that differ materially from conventional investor-owned companies.

In many cooperatives, members may contribute capital not simply as investors seeking a financial return, but as customers, suppliers, workers, producers or other participants in the enterprise they collectively own.

We support MBIE's focus on proportionate regulation and believe the characteristics of the financial product, its purpose, and the relationship between an issuer and its members should be relevant considerations when regulatory requirements are designed.

This does not mean reducing appropriate investor or member protections. Rather, it means ensuring the framework recognises that not all forms of equity or ownership operate in the same way.

Key issues addressed

Our submission encourages MBIE to:

• Explicitly consider cooperatives, mutuals and other member-owned businesses in future capital markets reform.

• Support ownership-model neutrality so that regulation does not inadvertently create disproportionate barriers for particular ownership structures.

• Connect future consideration of the Financial Markets Conduct (Small Co-operatives) Exemption with the wider capital markets reform programme.

• Consider new and growing member-owned businesses when reviewing small offers and other proportionate capital-raising pathways.

Our overarching view is that capital markets reform should recognise capital formation as an ownership issue as well as an investment issue.

Read more submissions