Our recommendations

We recommend that, when public organisations are developing and implementing crisis-support initiatives that approve payments based on "high-trust", they:

1. ensure that criteria are sufficiently clear and complete to allow applicant information to be adequately verified; and
2. put in place robust post-payment verification measures, including risk-based audits against source documentation, to mitigate the risks of using a high-trust approach.

In relation to the Wage Subsidy Scheme, we recommend that the Ministry of Social Development:

3. test the reliability of a sample of the post-payment assurance work it carried out against documentary evidence held by applicants; and
4. prioritise remaining enforcement work, including:
   • seeking written confirmation from applicants (which could be targeted towards larger or risk-indicated applicants) of compliance with the eligibility criteria and the obligations of receiving the subsidy; and
   • pursuing prosecutions to recover funds and/or to hold businesses to account for potentially unlawful behaviour.

We recommend that the Ministry of Social Development, the Inland Revenue Department, the Ministry of Business, Innovation and Employment, and the Treasury:

5. carry out timely evaluation of the development, operation, and impact of the Wage Subsidy Scheme and use the findings to inform preparation for future crisis-support schemes.