2022 CSA update – Pathway to implementation of narrowed transition scope


In February RSPs gave us feedback on the high-level future state proposals for key issues dealt with under the existing CSA. The proposals were informed by the understand and design phase insights and published in December 2020. That feedback suggested the broader transition scope might no longer be appropriate in the context of the 2022 CSA transition.

In early March we published our proposal to narrow the 2022 CSA transition scope. The idea was to focus on those changes required to ensure the 2022 CSA is fit for purpose under the new regulatory regime from 1 January 2022.

We hosted an all RSP feedback session regarding our proposal to narrow the transition scope on Wednesday 24 March. RSPs in attendance were:

  • Broadly supportive of narrowing scope - were supportive of narrowing scope and asked for an opportunity to consider a mark- up of our proposed in-scope changes to the existing CSA; and
  • Changes to other key legislation - asked us to consider making additional changes where key legislation has changed since execution of the existing CSA (e.g. Health and Safety); and
  • Consider behavioural solutions for change management issues - agreed there is an opportunity to explore behavioural solutions for current change management pain points before we look to contractual change. [Note: RSPs told us they want to ensure we keep the dialogue going on change management.]

What’s happening?

We’ve narrowed the 2022 CSA transition scope to:

  • the essential regulatory changes 2022 CSA is fit for purpose under the new regulatory regime from 1 January 2022; and
  • updating existing references to Health and Safety, privacy, and contracts legislation to ensure we refer to the most up to date legislation in these areas.

We will rely on the Required Change mechanic to implement these essential regulatory changes. This mechanic requires consultation with RSPs, CIP approval and at least 20 business days’ notice to RSPs.

What’s the detail?

We believe it is important to continue our collaborative engagement with RSPs in finalising the changes for which we seek CIP’s formal approval. With that in mind and based on RSP feedback, here is a draft mark-up of the general terms of the existing CSA identifying the changes we’d propose based on the narrowed scope.

Please give us your feedback (if any) on this draft mark-up at by COB Wednesday 26 May. [Note: This timing ensures you have a 4-week period over which to review and consider the draft mark-up.]

Once we’ve had an opportunity to review and collate feedback received, we will publish a summary of all RSP feedback. This summary will also be provided to CIP.

Important – the draft mark-up is password protected. Earlier in the transition process, you gave us feedback there might be a need at some stage for password protection of the content published as part of this process. We think this is required in relation to the draft mark-up. As a result, you will only be able to access this document using your SP website password (i.e. you will need to register as a SP website user if you haven’t already to gain access).

Indicative timeline

During the all RSP feedback session at the end of March, we said we’d provide an indicative timeline setting out the key milestones and associating timings from now until the proposed changes are intended to take effect from 1 January 2022. The indicative timeline is set out below.


The timeline is subject to, and may be influenced by, two key factors:

1. CIP engagement - We are already in discussion with CIP on this matter and have recently provided a draft mark-up for CIP’s informal review and consideration. The timeframes in relation to CIP engagement are aspirational and will depend on timely input from us and the nature of any follow-up information requested by CIP.

2. MBIE decision on declared service terms - At this stage, it is not clear what approach MBIE intend to take on applicable terms for declared services. If MBIE decide to focus on matters relating to pricing and service description only, we may consider including any associated changes required to the existing CSA as part of this transition process (e.g. as a stand-alone schedule).

Proposed approach to prioritised areas out of transition scope

The below table outlines the subject areas prioritised at the 'understand' phase of this transition and how we will progress these matters outside of the transition process.

table 2

What’s Next?

If you have feedback on the draft mark-up of the existing CSA, please let us know at by COB Wednesday 26 May.


If you have any queries, please get in touch with us at