Commerce Commission
Generally, we wish to flag that, from a timing perspective, there is potential for variability between the first and subsequent returns due to the ongoing changes to the CCCFA. We see the biggest areas for variability occurring due to the changes to variations and the likely higher usage of exemption pathways. MBIE have suggested the earliest the industry will receive final wording will be in February 2023 and the full benefit of any changes might not be realised until much later into 2023. In this context, the Commission should take into account that populations may shift between the first and subsequent returns, and that if they do, further thought may need to be given to exemption metrics if they are to be an effective tool.