Our submission on the Jobseeker Support and Accommodation Supplement Bill
Our presentation to Select Committee.
Download our full submission (254 kb)
CCS Disability Action has made a formal submission on the Social Security (Jobseeker Support and Accommodation Supplement) Amendment Bill. We understand why targeting income support to the people who most need it is necessary. We do not support the way this Bill goes about it.
The Bill applies a new Parental Assistance Test to every type of Jobseeker Support, including the Health Condition, Injury, or Disability category. It offers no exemption for young disabled people who already hold a medical certificate confirming they cannot work. That is the single most important problem we have raised with the Select Committee.
Our National Policy Analyst, Phoebe Eden-Mann, lodged the submission on 10 June 2026. Below, we explain our main concerns and the changes we are asking Parliament to make.
What does the Bill change?
The Bill amends the Social Security Act 2018 and puts two Budget 2025 decisions into effect (New Zealand Parliament).
From 2 November 2026, most single 18 and 19-year-olds without children must pass a Parental Assistance Test to get Jobseeker Support. The test has two parts. The first is a parental income test, with the limit currently set at $65,529. The second is a parental support gap test (Ministry of Social Development). It applies to all types of Jobseeker Support, including the Health Condition, Injury, or Disability category.
From 1 April 2027, the entry threshold for some homeowners to get the Accommodation Supplement rises from 30% to 40% of their base rate. People on New Zealand Superannuation, Veteran's Pension, and the Supported Living Payment keep the 30% threshold (New Zealand Parliament).
Why does the missing medical exemption matter so much?
To receive Jobseeker Support on health or disability grounds, a person must give Work and Income a medical certificate from a health practitioner. The certificate confirms their condition affects their ability to work (Work and Income).
The Supported Living Payment would protect these young people from the test. But it is set deliberately high. A person must be permanently and severely restricted in their ability to work, with that incapacity expected to last more than two years (Work and Income).
This creates a contradiction at the heart of the Bill. A young disabled person can be medically certified as unable to work, yet still not meet the Supported Living Payment threshold. Their condition may fluctuate, may not be classed as permanent, or may not yet have lasted two years. These people are directed to Jobseeker Support instead. The Bill then applies a work-incentive test to them. Yet their own medical certificates say they cannot work.
A test built on work incentives cannot sensibly apply to people who are not work-ready on medical grounds. We are asking Parliament to exempt young people who hold a medical certificate and receive Jobseeker Support on health or disability grounds. This would mirror how Supported Living Payment recipients are already treated.
Why is it wrong to base eligibility on a parent's income?
Basing a young disabled person's eligibility on their parents' or step-parents' income ignores the higher costs disabled people and their whānau already carry. It also puts at-risk young people in danger.
Disabled people and their families face higher living costs and lower incomes. Material hardship affects 26.9% of disabled children, more than double the 12.7% rate for non-disabled children (Whaikaha). It affects 27.5% of children in households with a disabled member, compared with 8.4% in households with none (Child Poverty Action Group).
The income limit treats every family the same. A family earning just over $65,529 is deemed able to support an 18-year-old, whatever their disability-related costs or the young person's support needs. For whānau already carrying the extra costs of disability, that assumption does not hold.
The parental support gap test is meant to protect young people who cannot rely on family. But the bar to prove this appears very high. A young person may need to show they have been made to leave home, or that family violence has occurred, before they qualify. Disabled people experience violence and abuse at much higher rates than non-disabled people. Rates are four to five times higher for disabled women and disabled children (VisAble). A test that forces a young disabled person to stay financially dependent on a parent they cannot safely rely on is a safety risk, not a safeguard.
If a parental income test proceeds at all, it must adjust for disability costs, exclude step-parents, and publish clear, safe criteria for young people who cannot rely on family.
How does the Bill put disabled homeowners at risk?
Raising the Accommodation Supplement entry threshold puts disabled homeowners on low incomes at risk of losing their homes.
The Accommodation Supplement is one of the few supports that helps disabled people on low incomes stay in their own homes. Article 19 of the United Nations Convention on the Rights of Persons with Disabilities recognises the right of disabled people to live independently and to be included in the community (United Nations).
Disabled people also face a wide and persistent labour market gap. In the June 2025 quarter, the employment rate for disabled people aged 15 to 64 was 38.2%, compared with 78.5 % for non-disabled people (Whaikaha). That gap of 40.3 percentage points has not shifted since the series began in 2017.
A disabled homeowner may hold a significant asset, their home, while living on a very low and largely fixed income. Suggested responses, such as taking in a tenant or refinancing, do not work safely for many disabled people. Taking in a tenant raises real safety concerns. Refinancing is daunting for a disabled person on a low income who faces major barriers to work. The likely result is that some disabled homeowners will eventually lose their homes.
The Bill keeps the 30% threshold for Supported Living Payment recipients. But it applies the 40% threshold to those on Jobseeker Support with a health condition or disability. This creates a two-tier system within the disability community. The two benefits do not divide disabled people into those who need housing security and those who do not. They divide them by an administrative threshold. We are asking Parliament to keep the 30 % threshold for Jobseeker Support recipients too, as it already does for Supported Living Payment recipients.
What does the Government's own analysis say?
The Bill should not proceed in its current form when the Government's own analysis raises clear concerns.
The Regulatory Impact Statement raises concerns about the approach, including the position of disabled young people. It also records that disability organisations were not consulted during policy development (Ministry of Social Development).
Separately, three community groups have said the Prime Minister's office received no advice that plentiful jobs exist for the young people affected. Child Poverty Action Group, Auckland Action Against Poverty, and Kick Back all raised this. CPAG's Isaac Gunson said the strategy "won't work in an economy with unemployment at a nine-year high, and with roughly four jobseekers for every job ad" (Child Poverty Action Group).
Good law-making relies on sound evidence and proper analysis. Here, disabled people were not consulted. The central premise, that there are jobs for these young people to move into, is not supported by the advice the Government holds. For young disabled people, the test does not create a pathway into work. It simply moves financial responsibility onto whānau who are already stretched.
Why does the volume of change concern us?
This Bill does not arrive on its own. Disabled people and their whānau are facing a steady run of policy and legislative changes, each considered in isolation. On its own, any one change may look modest. Together, they add up.
The welfare, housing, and support changes now moving through Parliament land on the same households at the same time. These are households that already carry higher costs and lower incomes. Material hardship affects 26.9% of disabled children, more than double the rate for non-disabled children (Whaikaha). The employment gap of 40.3 percentage points has not shifted since 2017 (Whaikaha). When change stacks on change, the pressure builds on the people least able to absorb it.
The problem is that no one is measuring the combined effect. Each Bill is assessed against its own narrow test. No single analysis shows what all these changes, taken together, mean for a disabled person or their whānau. Parliament cannot make a fair call on this Bill without seeing that full picture. This is why we have asked Parliament to model the cumulative impact of this Bill alongside other measures affecting disabled people, and to carry out a full disability rights impact assessment. Disabled people deserve to know the total weight of what is being asked of them, not just one piece at a time.
How does the Bill affect whānau hauā and tāngata whaikaha Māori?
The Bill's impacts fall hardest on whānau hauā and tāngata whaikaha Māori, who already face the widest gaps.
The NEET rate, the share of young people not in employment, education, or training, was 45.9% for disabled young people aged 15 to 24. That is more than four times the rate for non-disabled young people (Whaikaha).
When a young disabled person cannot find work in a labour market that consistently excludes them, removing their income support does not change the labour market. It transfers the cost to their whānau. For disabled Māori, who face the widest gaps of all, this deepens an existing inequity. New Zealand's obligations under Te Tiriti and under the UNCRPD point the same way. Disabled people, and Māori disabled people in particular, should be involved in decisions that affect them.
What are we asking Parliament to do?
We have asked the Select Committee to make these changes before the Bill proceeds:
Introduce a medical exemption from the Parental Assistance Test for young people who hold a current medical certificate confirming they cannot work.
Reconsider applying the test to Jobseeker Support with a health condition or disability, and resolve the contradictions in the Bill first.
Set a disability-adjusted income limit if a parental income test proceeds.
Publish the parental support gap test criteria, with clear, safe pathways for young disabled people.
Exclude step-parents from the income test, as happens for child support.
Keep the 30% Accommodation Supplement threshold for Jobseeker Support recipients with a health condition or disability.
Require a full disability rights impact assessment, consistent with UNCRPD Article 4(3).
Model the combined effect of this Bill alongside other measures affecting disabled people.
These problems are fixable. We urge the Committee to make these changes so the welfare system protects, rather than penalises, disabled rangatahi and their whānau.
Frequently asked questions
What is the Social Security (Jobseeker Support and Accommodation Supplement) Amendment Bill?
It is a Bill that changes the Social Security Act 2018. From 2 November 2026, it brings in a new Parental Assistance Test for most 18 and 19-year-olds seeking Jobseeker Support. From 1 April 2027, it also raises the Accommodation Supplement entry threshold for some homeowners from 30 % to 40 %.
What is CCS Disability Action's main concern with the Bill?
The Bill applies a work-incentive test to young disabled people who hold a medical certificate confirming they cannot work. That is a contradiction. We are asking for a medical exemption so these young people are not caught by the test.
Why can't these young people just get the Supported Living Payment instead?
The Supported Living Payment is set deliberately high. A person must be permanently and severely restricted in their ability to work, with that incapacity expected to last more than two years. Many disabled people who cannot work do not meet that bar. Their condition may fluctuate, may not be classed as permanent, or may not yet have lasted two years. They are directed to Jobseeker Support instead, where the new test would apply.
Why is basing eligibility on a parent's income a problem?
It assumes every family can support an 18 or 19-year-old, whatever their situation. Disabled people and their whānau already carry higher costs and lower incomes. The income limit makes no allowance for that. It also draws in step-parents, whose income is not counted for child support. And for young people who cannot safely rely on family, the bar to prove this appears very high, which is a real safety risk.
Does the Bill affect disabled homeowners?
Yes. Raising the Accommodation Supplement threshold protects Supported Living Payment recipients but not those on Jobseeker Support with a health condition or disability. The Accommodation Supplement is one of the few supports that helps disabled people on low incomes stay in their own homes. We want the same protection extended to both groups.
Why does CCS Disability Action say the Bill creates a two-tier system?
The Bill keeps the 30 % Accommodation Supplement threshold for Supported Living Payment recipients but applies the 40 % threshold to those on Jobseeker Support with a health condition or disability. This splits the disability community by an administrative line, not by actual housing need. People on the wrong side of that line have needs that are no less real.
What exactly is CCS Disability Action asking Parliament to do?
We have asked the Select Committee to make eight changes before the Bill proceeds: introduce a medical exemption; reconsider applying the test to Jobseeker Support with a health condition or disability; set a disability-adjusted income limit; publish the parental support gap test criteria with safe pathways; exclude step-parents; keep the 30 % Accommodation Supplement threshold for Jobseeker Support recipients too; require a full disability rights impact assessment; and model the combined effect of this Bill alongside other measures affecting disabled people.
Does CCS Disability Action oppose all welfare reform?
No. We support targeting income support to the people who most need it, and we are pleased Parliament is looking at how the system works for young people and homeowners on low incomes. Our concern is with how this Bill goes about it. These problems are fixable, and we have set out the changes that would fix them.
What happens next?
The Select Committee is considering submissions before the Bill proceeds. We have asked the Committee to make our recommended changes first.
About CCS Disability Action
CCS Disability Action is the largest pan-disability support and advocacy organisation in Aotearoa New Zealand.
We support people with all types of impairments and have been working alongside disabled people since 1935.
We are at the forefront of service provision, advocacy and information sharing in the disability sector. We partner with disabled people, their families and whānau to enable them to have choice and control in their lives. Our vision is to see every disabled person and whānau hauā interwoven into the lives of their whānau and community.