NZ fintech Dosh is planning to drill into the home loan advice market and other areas as it considers whether or not to reapply for banking registration.
The NZ fintech found itself at a crossroads last year when the Reserve Bank (RBNZ) turned down its banking registration application saying Dosh’s proposed banking model was not viable under the current legislation.
The issue, according to Marsh, was that Dosh had pitched a digital banking model – similar to the likes of UK-based Monzo and Australian Up Bank – that didn’t offer credit.
“We’re New Zealand’s Monzo,” Marsh told interest.co.nz.
The United Kingdom-based Monzo is a fully online bank founded in 2015 as a challenger bank that now has over 16 million customers across the UK and Ireland. Monzo is entirely digital with no physical branches and offers free personal current accounts, joint accounts and teen/kids accounts, alongside paid monthly upgrade plans that add insurance, interest boosts and rewards.
“The model we put forward was a little different from previous traditional banks that had been registered in New Zealand. That was because we had seen that there’s been success in other markets such as the United Kingdom where new competition and innovation has really been driven by digital banks,” Marsh said.
Marsh described the digital bank model as leaning towards a transactional one where a customer gets an account, card and potentially savings offerings.
“But effectively you scale with a digitally transactional offering that doesn't include credit,” he said.
“So when I say credit, I mean raising customer deposits and lending them out. And the reason for that is that that's a different capability and different product set that requires credit risk management and building both sides of the balance sheet. So seeing what had been successful overseas in creating competition and innovation, that's the approach we looked to bring to New Zealand.”
‘Pause and focus’
Dosh started the bank registration process in July 2024 and submitted a full banking registration application in February 2025. The RBNZ declined Dosh’s application in August 2025.
“The Reserve Bank said, based on this model, it's a decline,” Marsh said. He added that the RBNZ had told the fintech they’d be open to Dosh reapplying or updating their application with a model that meets the requirements under the current legislation – which would effectively be Dosh taking on credit.
“The reason we didn't share it straight away is that when we got that feedback from the Reserve Bank, we effectively needed to decide: are we going to update our application and resubmit it, or are we going to pause?” he said.
“And we decided, because there’s some really exciting things happening with Dosh specifically in terms of our relationship with One NZ, that we would [rather] pause and focus on that in the meantime while we let the regulatory legislation changes take place.”
The regulatory changes Marsh is talking about are part of the rollout of the Deposit Takers Act (DTA), which is set to be fully implemented by December 2028. The new framework will oversee the regulation of all banks and NBDTs in NZ under a single prudential regime.
One of the changes that will be implemented when the DTA comes into full effect is the significant drop in capital required for full banking registration.
The RBNZ requires banks to have an absolute minimum of $30 million of regulatory capital, which financial institutions have to prove when they apply for banking registration. This is because bank capital is funding that's first in line to absorb any losses banks may incur.
Following the DTA coming into effect in 2028, the RBNZ will only require $5 million of minimum regulatory capital, a decrease of $25 million.
Marsh said Dosh hasn’t yet decided if it will reapply for banking registration under the current legislation, where the capital requirements still require proof of $30 million in regulatory capital.
Instead, the fintech could wait for the new legislation in 2028.
“We’re considering the best way forward for our business at this stage,” Marsh said.
Home loan focus
Marsh said Dosh is concentrating on promoting its home loan offers and partnership with One NZ.
Launched in February, the ‘One NZ dosh’ Visa card allows people to earn 1% of their transactions back in ‘phone dollars’, which they are then able to spend on One NZ products.
Dosh recently became registered by the Financial Markets Authority (FMA) to provide financial advice for home loans and the fintech also provides home loans through Westpac, another partnership that began last year.
Marsh said Dosh was focused on providing mortgage broker advice that gave customers competitive interest rates. He said providing mortgage broker advice had proven popular but he wouldn’t share numbers.
“Home loans are a topic where people do want advice and support, and so we're really pleased to be able to go deeper with our customers and provide them a great offer at a time when users are struggling,” Marsh said.
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