This analysis draws on deep knowledge of empirical research on quality ECE and on evidence about what best supports positive outcomes for children in teacher‑led early childhood settings. It also reflects the experience and insights contributed by OECE members and our Early Childhood Advisory Committee.
1. Context and Purpose of This Response
The Ministry of Education is developing policy options to implement two Ministry for Regulation recommendations relating to staffing:
– “Allow greater flexibility in workforce qualifications…” rather than developing a strategy to attract and retain ECE‑qualified teachers in services struggling to recruit or keep staff, or addressing service reluctance to employ qualified teachers due to cost pressures, profit margins, regulatory settings, or other operational decisions.
– “Ensure the person responsible requirements are practical…” rather than ensuring these requirements reflect best practice for child safety, education, and care, and rather than reversing what was intended to be a temporary measure introduced during a staffing shortage that allowed primary‑trained teachers to act as a Person Responsible.
In September 2025, the Office of Early Childhood Education (OECE) provided the Ministry with a paper offering advice and analysis on these recommendations. It is available here: Reducing Teacher Qualification Requirements
This paper offers further comment and guidance in light of the policy options currently under development, to address the Ministry for Regulation’s recommendations on increasing qualification flexibility and ensuring the Person Responsible requirements reflect what is workable for service providers.
2. Why ECE Qualifications Matter
3. Risks the Ministry Must Put Before Ministers and Cabinet
4. Policy Options That Better Support Children and the Workforce
5. Our Recommendations for Amendments to Regulation 44
