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Consultation was undertaken from 29 November 2021 to 11 March 2022.

About the submissions 

We received 177 written submissions.

Of the total submissions:

  • 25 indicated to have an iwi affiliation (school or individual submission).
  • 118 from state or state-integrated school
  • 16 from private schools
  • 120 (school and individual submissions) indicated that their school has previously enrolled international fee-paying students. Of the 120:
    • 97 still currently enrol these students.
    • 58 had short-term (maximum of three months) tour groups of international fee-paying students pre-COVID.

The table below describes the year levels of the schools who have made a submission.

Type of school Total Percentage %

Composite Year 0 - 13



Contributing primary Year 1 - 6



Full primary Year 1- 8



Intermediate Year 7 - 8



Secondary Year 7 - 15



Secondary Year 9 - 15



Was not on behalf of a school or did not answer



Grand Total



The 54 who did not make a submission on behalf of a school were either:

  • individuals who are involved in international education such as teachers, international directors or agents.
  • submissions on behalf of an organisation, peak body, union or regional economic organisations.

We also organised some workshop sessions that included:

  • schooling peak bodies
  • international education peak bodies
  • members of Schools International Education Business Association (SIEBA) which are schools with international fee-paying students
  • members of the Regional International Education Network Aotearoa (RIENA)
  • other individuals who are generally interested in international education.

Summary of responses

The discussion document for public consultation outlined the current situation, problem definition and proposals for change. It also asked if there were any other forms of restriction that we should consider, for example on under Year 7 or only restricting for short-term students (3 months or shorter) in tour groups.

Discussion document

Respondents were able to answer all questions or select only the questions that they want to answer. Below is the summary of responses for each question.

Do you agree with the characterisation of the current situation? 

  • 45 submissions or 25% agreed or strongly agreed with it. When answering the question why they agreed, they indicated that they agreed with the facts stated and the benefits mentioned.
  • 78 submissions or 45% disagreed or strongly disagreed with it. When answering the question why they disagreed, the main reasons given were focussed on the problem definition. Some respondents indicated they considered the arguments mentioned in the document were based on evidence. Others indicated they believe international students are not a distraction from domestic students. Lastly, some of them believe there is a lack of government resources and that is why international education is needed.
  • 46 submissions or 26% were neutral. They indicated that the information provided was broadly accurate but was not nuanced enough. Some said that more information is needed regarding the current situation.

Have there been other benefits for your school? 

Respondents mentioned a range of benefits of the current policy settings. 

The top benefits they mentioned are:

  • The revenue that schools receive from international fee-paying students creates additional benefits beyond what a school can offer within its normal operations grant and therefore improves the quality of education for all students.
  • International fee-paying students help promote global citizenship for students at a young age to understand other cultures and languages, and to provide a personal connection to the world. Students will create international connections, which benefits them in future life.
  • International fee-paying students at primary and intermediate level provide a critical pathway into local secondary schools which provides immediate and long-term economic benefits. Students who come to New Zealand at a younger age will develop a stronger English Language proficiency and integrate into the New Zealand culture more seamlessly.
  • Having international fee-paying students help strengthen New Zealand’s international relations and reputation, which can have a positive effect on New Zealand’s international trade and relations.
  • International Fee-paying students supports local businesses and the local community financially and socially. 

Do you agree with the described problem definition? 

  • 11 submissions or 6% agreed or strongly agreed with it. The main reason respondents agreed with the problem definition was because they believe that international education creates inequalities between high and low decile schools. Others indicate they believe that short-term study tours are the least desirable and are more disruptive.
  • 144 submissions or 81% disagreed or strongly disagreed with it. Their main argument was that the problem definition was not based enough on evidence or data. Respondents also indicated that these issues are not specific to primary and intermediate schools, as these issues apply to secondary schools also. Here are some of the other responses as to why they disagreed:
    • They do not believe that international fee-paying students are a distraction from educating domestic students. They indicate the opposite as international fee-paying student benefit the education of domestic students via the development of global citizenship skills.
    • Enrolment of international fee-paying students also benefits domestic student as the extra revenue that primary and intermediate schools get from it is used to strengthen the education for all students. Some schools rely on international student revenue to meet the operational needs of their school. A couple of respondents indicated that low decile schools receive more funding and high-decile school need to find the funding from somewhere else.
    • They do not believe there are additional pressures on teachers. The revenue generated is often being used to recruit additional teachers, for example, ESOL (English to Speakers of Other Languages) teachers to ensure the pressure on teacher does not increase.
    • International fee-paying students under Year 9 do not contribute or barely contribute to migration pressures.
  • A couple of respondents indicated additional issues with the current situation. Some indicated that their view is that schools do not receive enough funding from the Government. This creates a reason for schools to look for third-party generated funding. Another issue raised is that the minimum age for a student to come to NZ without a parent or legal guardian is too low. 

Do you agree with the proposed changes? 

  • 12 submissions or 7% agreed or strongly agreed with it. The main reason used to support their answer was that it creates additional stress and pressure on teachers. It takes additional time to support these children, for example to support with their mental wellbeing and English language. The other argument used is that there is an inequity between schools with and without international fee-paying students. It is hard for some schools to get international fee-paying students due to their capacity or location.
  • 147 submissions or 83% disagreed or strongly disagreed with it. Most of them believe no change is needed and call for the proposal to be withdrawn. They indicated that there are no problems to be solved and if there are any risks, the value and benefits of international education outweigh that. Some indicated that it is good that schools have the responsibility to decide if international education suits the needs of their students and community. Lastly, they indicated that the problems identified will not be resolved by restricting the enrolment of under Year 9, particularly the inequity within the education system, migration pressures and the pressure on teachers. 

If the enrolment of international students under Year 9 is restricted, who should this be applicable to and why? 

The question included different scenarios if we were to restrict enrolment of these students:

  1. State and state-integrated schools, private schools or both
  2. Under Year 7 or under Year 9
  3. For individual students, dependent students and/or tour group students 

On whether to restrict it to state, state-integrated or private schools

  • 96 submissions or 54% did not make any selection. This may be because they are against any form of restriction.
  • 81 submissions or 46% have answered this question:
    • 53 submissions or 30% who answered this question indicated that they would prefer it to be applicable to all state, state-integrated and private schools. They said this creates fairness and equity within the education system. Another reason given is that the problems identified, such as migration pressure, will not be resolved as they will still be able to enter the country.
    • 7 submissions or 4% indicated that they prefer it to be applied on state and state-integrated schools only. The main reason given was that private schools are independent and responsible for their own enrolment scheme.
    • 21 submissions or 12% indicated that they prefer it to be applied on private schools only. Their reason is that it will reduce the inequity between state and state-integrated schools and private schools.

On whether to restrict to under Year 7 or Year 9

  • 119 submissions or 67% did not make any selection. This may be because they are against any form of restriction.
  • 58 submissions or 33% have answered this question:
    • 47 submissions or 27% think it should only be applicable for the enrolment of international fee-paying students under Year 7. They indicated that this would be the least-worst situation as it will allow schools to maintain some of the benefits of international education. The other reason used is that under Year 7 students are too young, which poses additional wellbeing risk for them.
    • 11 submissions or 6% think it should be applicable for the enrolment of international fee-paying students under Year 9. The only reason provided was that the problem definition will likely be resolved by the restriction.

On whether to restrict long term students (individual or dependent students), tour groups or both

  • 112 submissions or 63% did not make any selection. This may be because they are against any form of restriction.
  • 65 submissions or 37% have answered this question:
    • 37 submissions or 21% indicated that they would prefer it to be applicable to tour group students only. They said that there are less benefits with tour groups as they are not likely to pathway into secondary and will hardly support the development of global citizenship skills of domestic students. They added that tour groups add extra resourcing and schooling pressures. Lastly, they also indicated that it is harder to integrate tour group students with domestic students.
    • 15 submissions or 8% preferred it to be applicable to both. Very few have explained their selection. Of those who provided a reason, they believe both types of students create resourcing and schooling pressures.
    • 13 submissions or 7% preferred it to be applicable to long-term students only. Very few explained their selection. Of those who provided a reason, they said that tour groups benefit business more, like the tourism industry.