New ZealandRecertification audit · Nurses
Authentic Recertification Evidence: The Nursing Council AI Declaration Explained
What you actually sign when you send audit evidence to Te Kaunihera Tapuhi o Aotearoa, what the Council has and has not said about AI tools, and how to write professional development records and pou examples that are unmistakably your own.
Reviewed October 2026 against Nursing Council of New Zealand audit guidance, audit forms and FAQs, the HPCA Act 2003 and Office of the Privacy Commissioner guidance
Short answer: When you send recertification audit evidence, the Nursing Council's form asks you to declare that it is true, correct and authentic, represents your own work, and has not been created by artificial intelligence. The Council's guidance says audits require "authentic, personal reflection" and recommends talking to peers, mentors or senior nurses instead of using AI. It does not say whether spell checkers, dictation or translation tools are acceptable, so the safe course is to write every example and PD entry yourself, from your own practice, and ask the Council before using any tool you are unsure about.
Key takeaways
- The AI wording is part of a formal audit declaration that the Council's own FAQ calls a legal statement, and the form names the HPCA Act section 172 offence alongside it.
- The Council's guidance warns that using AI without disclosing it "may lead to professional misrepresentation and inaccuracies".
- The Council has not published rules on spelling, grammar, dictation or translation tools. Where it is silent, keep tools away from the content and check with the audit team.
- Authentic evidence is specific: a real situation, your own actions and reasoning, a real outcome and a dated, honest PD log.
- As of October 2026 the Council has paused audit evidence while it reviews continuing competence requirements, but your annual APC declaration still has to be true and correct.
Where things stand in October 2026
Our Nursing Council recertification guide covers the full set of continuing competence requirements: 450 practice hours and 60 hours of professional development in the previous 36 months, and the standards of competence for your scope. This article goes into one part of it in depth: the authenticity and AI declaration that sits at the end of the audit form, and how to produce evidence that passes it comfortably.
First, an important update. The Council's recertification audit page now carries a notice headed "Temporary pause on recertification audit". It says the Council "has committed to undertaking a strategic review of the continuing competence requirements" for enrolled and registered nurses, and that all nurses who have been selected for audit "are no longer required to provide audit evidence to the Council". The notice gives no end date and does not say how audits will look when they resume.
The same notice says you must continue to apply for your annual practising certificate (APC) in the usual way, including the declaration that you meet the continuing competence requirements. The Council's continuing competence page states that your APC declaration "confirms that the information you are providing is true and correct". So you still need a real PD record and real practice to point to. The audit guidance (Version 2.0, October 2025) and the audit forms remain published, and they are the clearest statement of what the Council expects authentic evidence to look like.
That makes this a good time to build habits rather than a reason to stop. If audits restart, or the review changes the requirements, nurses who have kept honest, specific records all along will have the least work to do. For the wider portfolio, from storage to retention, see our audit-ready portfolio checklist.
APC declaration
Made by every nurse renewing a practising certificate. You declare whether you meet the practice hours, professional development and competence requirements. False or misleading information can lead the Council to decline your APC.
Audit declaration
Signed by enrolled and registered nurses who send audit evidence. This is where the wording about authenticity, your own work and artificial intelligence appears, together with the warning about section 172 of the Act.
What the declaration actually says
The declaration appears on both the registered nurse and enrolled nurse recertification forms. Each part does a different job, so it helps to read it clause by clause. The wording below is quoted from the Council's form; the right-hand column is our plain-language reading.
| Clause on the form | What it means for you |
|---|---|
| "solemnly and sincerely declare … that the evidence … is true, correct and authentic" | Everything in the bundle, not just the examples, must be accurate and genuinely yours. "Authentic" goes further than "true": a true event written up by someone or something else is not authentic evidence of your reflection. |
| "it represents my own work and has not been created by artificial intelligence" | You are the author. The words, the structure of the reflection and the thinking come from you, not from a generative AI tool. |
| "my statement about the completion of my practice hours is true and correct" | Your 450-hour declaration must be accurate even though you are not asked for rosters or payslips. |
| "my summary of professional development hours is true and accurate" | Dates, activity names, hours and pou links must reflect what you actually did. No rounding up, no guessing, no activities outside the 36-month window. |
| "the evidence I have submitted in my competence assessment relates to my own nursing practice" | Examples must come from your practice, not a colleague's story, a textbook case or a composite you have invented. |
| False or misleading information "may lead to professional disciplinary action under the Act" | An inaccurate declaration is treated as a conduct matter under the Health Practitioners Competence Assurance Act 2003, not a paperwork slip. |
| Knowingly false declarations or non-genuine documents are an offence, with a fine "not exceeding $10,000 under section 172 of the Act" | Knowingly signing a false declaration, or supplying a document you know is not genuine, can also be a criminal offence. |
A senior nurse then signs a separate verification. They state that they have read your self-assessed evidence of competence and that, to the best of their knowledge, it "is an accurate reflection of how they practise" and that you meet the standards for your scope. Where there is no senior nurse in your setting, your employer can verify. Your verifier is putting their name to your evidence too, which is one more reason it has to describe practice they would recognise.
The Council's FAQ on the 2025 audit requirements describes a self-declaration as "a legal statement or confirmation made by you" that the information is true and correct. Typing your full name and the date is accepted as a signature if you cannot sign electronically.
What the Council says about AI, and where it is silent
Beyond the declaration itself, the Council has addressed AI in three places: the audit guidance, the recertification audit web page and the audit FAQ. Taken together, its position is consistent.
- The guidance, under the heading "The use of artificial intelligence", notes that "there is a greater temptation to use AI to generate evidence".
- It states that "Competence audits require authentic, personal reflection."
- It warns that "Using AI without disclosing that you have done so may lead to professional misrepresentation and inaccuracies", and that AI-generated examples "may fail to address the complexities of nursing practice".
- The audit web page adds that you must use actual examples from your nursing practice to demonstrate your competence "without relying on AI".
- The guidance and FAQ both point you to people instead: "check in with your nursing peers, mentors or senior nurses", and reach out for support if you need help to reflect. The guidance adds: "Self-reflection provides the best insights that AI cannot replace."
What the Council has not done is publish a list of acceptable and unacceptable tools. Its audit guidance does not mention spelling or grammar checkers, dictation, translation tools or accessibility software. It also does not explain how you would disclose AI use if you had used it. The 2025 standards of competence expect digital capability (descriptor 4.8 of the registered nurse standards refers to "digital capability and online health literacy", and the enrolled nurse standards have a similar descriptor), so the Council is not against technology in practice. Its concern is narrower: who authored the evidence of your competence.
The table below sets out common uses. Where the Council is silent we say so, and give the cautious approach we would take.
| Use of a tool | What the Council says | Our suggested approach |
|---|---|---|
| Asking a chatbot to write a pou example or reflection | Directly covered. The declaration states evidence "has not been created by artificial intelligence". | Do not do it, even as a "first draft" you plan to edit. |
| Asking AI to "improve", reword or expand your own draft | Not addressed by name. The guidance warns about undisclosed AI use and requires your own work. | Avoid. Rewritten text is no longer in your words, and the declaration has no "edited by AI" option. |
| Generating a PD log, hours or pou links | Covered by "true and accurate" PD summary and the AI wording. | Build the log yourself from certificates, rosters and calendars. |
| Basic spell check that flags misspelt words | Silent. | Fixing individual typos in words you wrote is unlikely to change authorship, but turn off sentence rewriting and "suggested phrasing" features. |
| Dictation (speech to text) of your own account | Silent. | Your words, transcribed, remain your words. Avoid tools that summarise or rephrase what you dictate. |
| Translating a draft written in your first language | Silent. | Ask the audit team before relying on machine translation, and say what you used. A trusted colleague reading your English draft is safer. |
| Assistive technology for a disability | Silent. | Contact the Council before you start and explain what you need. Record its answer. |
The Council's audit team is reachable at audit@nursingcouncil.org.nz. A short email describing the tool and how you plan to use it, sent before you write, protects you far better than a guess. Keep the reply with your portfolio.
Scenario: you write your pou 3 example yourself, then paste it into an AI tool and ask it to "make it sound more professional". Can you still sign the declaration?
Scenario: a colleague talks through a difficult discharge with you, and you then write it up as your example. Is that authentic?
Scenario: you cannot remember the exact date of a study day from two years ago, so you pick a likely month. Is that acceptable?
Why authenticity matters
It would be easy to see the AI clause as a box to tick. In practice it connects to three things the Council relies on.
The law
Recertification programmes exist under section 41 of the HPCA Act. Section 27(3) lets the Registrar or Council decline an APC if information in the application is false or misleading, and the audit form names the section 172 offence.
The Code of Conduct
Integrity is one of the four values underpinning the Code: "consistently acting according to values and principles, and being accountable and responsible for our actions". The Code warns that failing to uphold its standards "could lead to a disciplinary investigation".
Public protection
The audit is a check on your self-declaration. If evidence is not authentic, the Council learns nothing about your real practice, and the safeguard the public relies on stops working.
There is also a practical reason. Generated text tends to read like a restatement of the standard: plenty of values, no particular patient, no particular shift, nothing that went wrong. The Council's guidance makes exactly this point when it says AI-generated examples "may fail to address the complexities of nursing practice". Your verifier has to say the evidence is an accurate reflection of how you practise. Generic text makes that harder for them to sign, and harder for an auditor to accept without asking for more.
Finally, honesty in your evidence is part of the same professional duty as honesty in clinical records. The Code of Conduct asks nurses to "keep clear and accurate records" and never to tamper with original records. The standards of competence carry the same expectation into practice: descriptor 3.6 asks that documentation is "legible, relevant, accurate, professional and timely".
Writing an authentic professional development record
The PD record is where small inaccuracies creep in, usually from rushing at the last minute rather than from any intent to mislead. The audit guidance asks for each activity's date or period, topic, duration in hours and the pou it relates to. Certificates are not required. You can keep the record in MyNC or on the Council's Professional Development Record form.
- Gather the raw evidence first
Pull together certificates, course confirmation emails, in-service attendance lists, supervision notes and your calendar for the last 36 months. Write the log from these, not from memory.
- Record the time you actually spent
A course advertised as three hours that took you two and a half is two and a half hours. A conference day is the sessions you attended, not the time you were at the venue.
- Check each item meets the Council's test
The Council's continuing competence page says PD should be relevant and appropriate to your scope, development and work context, and should include more than the mandatory or core training your employer requires. Journal reading counts within a formal framework such as a journal club, and meetings count if they have an educational focus and documentation identifying the topic.
- Link each item to a pou honestly
Choose the pou the learning genuinely supported. One or two accurate links are better than six optimistic ones.
- Remove anything outside the window
The requirement covers the previous 36 months (three years). Anything older does not count towards it.
Here is how vague entries compare with entries an auditor can follow. The examples are illustrative.
| Weak entry | Why it is weak | Authentic entry |
|---|---|---|
| 2024 · Various online learning · 20 hours · All pou | No date, no topic, a round number and an implausible pou link. | 14 Aug 2024 · Online module: recognising sepsis in older adults · 2.5 hours · Pou 4 |
| Mandatory training · 12 hours · Pou 4 | Lumps core employer training together, and the Council asks for more than mandatory or core training. | Record each session separately with its real time, and make sure the rest of your 60 hours goes beyond this. |
| Reading journals · 10 hours · Pou 4 | Private reading outside a formal framework does not meet the Council's description. | Mar 2025 · Ward journal club: pressure injury prevention evidence (presented) · 1 hour · Pou 4 |
| Supervision · 2025 · 8 hours · Pou 6 | Accurate perhaps, but impossible to check. | Feb to Nov 2025 · Professional supervision, eight one-hour sessions (dates in supervision notes) · 8 hours · Pou 2, Pou 6 |
If your plan for next year's learning needs work, our professional development plan examples show how to set goals that produce useful, loggable PD.
Writing your own practice examples
For each pou you give one example from your recent practice, which the guidance defines as within the last three years. Registered nurses evidence six pou and enrolled nurses five. The FAQ asks you to describe specific interactions or situations, write in the first person ("I"), and avoid general statements that do not relate to your own practice. There is no word limit, but the FAQ says most nurses can give enough detail in 500 words or fewer per pou. You evidence each pou as a whole rather than every descriptor, and one example can support more than one pou because the evidence is read as a whole.
Our recertification guide shows how to structure a strong example for each pou, with a worked example. The method below is about the writing itself, and keeping it authentic from first note to final draft.
- Start from memory, not from the standard
List five or six shifts or pieces of work you still remember clearly: something that went well, something that went wrong, a conversation that changed your approach. Only then look at the pou and descriptors and match them. Writing from the descriptor first is how generic text happens.
- Capture notes close to the event
A two-line, de-identified note on the day ("frail older woman, family wanted to take her home, I arranged…") is worth more than a page written two years later. Keep these in your portfolio, not in a chatbot.
- Write the situation in a few sentences
Setting, your role, what was happening. Enough context for a stranger to follow, without names, dates of birth, NHI numbers, ward names or anything identifying.
- Describe what you did and why
This is the core. Your actions, the reasoning behind them, who you involved, and what you considered and decided against.
- Say what happened and what changed
The outcome for the person or whānau, and what you now do differently. If the outcome was not good, say so; honest reflection on a hard case is strong evidence.
- Read it aloud, then talk it through
Read the draft aloud: if it does not sound like you, rewrite it. Then talk it through with a peer, mentor or senior nurse, as the Council suggests, and correct anything they remember differently.
For pou 1 (Māori health) the FAQ makes a useful point: it does not depend only on direct clinical work with Māori. It is about your readiness, commitment and contribution to Māori health equity and Te Tiriti o Waitangi. Our guide to cultural safety and Te Tiriti requirements explains how this is framed across New Zealand recertification programmes. If you work in management, education, research or policy, the guidance accepts examples showing how you enable others to practise safely and meet the pou.
The FAQ is clear that examples written for the previous competencies will not demonstrate how your practice meets the pou, because the pou describe broad, interrelated practice rather than separate tasks. Use a real situation again if it fits, but write it afresh against the pou.
Generic versus authentic: three rewrites
The weak versions below are the kind of text that reads as generated, whether or not it was. Each strong version shows the same pou evidenced through one concrete situation. All are illustrative and shortened; your own will be longer and in your own voice.
- Weak
- "I always practise in a culturally safe way and respect the beliefs and values of all my patients. I reflect on my own culture and how it affects my nursing, and I work to reduce power imbalances."
- Strong
- "On a home visit to change a leg ulcer dressing, I began explaining the plan to the patient's daughter because she answered the door. The patient, a Samoan woman in her seventies, told me she preferred to make her own decisions and wanted her daughter there only for support. I realised I had assumed the family would want the younger person to lead. I apologised, sat at her level, and went through the options with her directly. She chose a dressing schedule that fitted her church commitments. Since then I ask each person at the first visit who they want involved and how."
- Why it works
- One visit, a named assumption the nurse made, the change in approach, and a lasting change in practice. Nothing identifies the patient.
- Weak
- "I use evidence-based practice and critical thinking in my work. I carry out thorough assessments and escalate concerns appropriately to ensure safe care."
- Strong
- "During an afternoon medication round I noticed a resident who is usually chatty was drowsy and had not touched her lunch. Her observations were within range apart from a slightly raised respiratory rate. I repeated them 30 minutes later and the rate had risen, so I reported my findings to the RN using our handover tool and recorded them. The RN reviewed her and arranged a GP visit; she was treated for a chest infection. I learned that a change from someone's usual behaviour is worth acting on even when most numbers look normal, and I now record a baseline note for residents I am allocated."
- Why it works
- Shows observation, clinical reasoning and escalation within the enrolled nurse scope, with the outcome and a practice change.
- Weak
- "As a nurse educator I demonstrate leadership by supporting staff development and promoting a culture of continuous improvement and patient safety."
- Strong
- "After two near-miss insulin errors on one ward, the charge nurse asked me to help. I sat with three of the nurses involved, without blame, and found that the new chart layout made the correction dose easy to misread. I raised this with the medication safety group, ran four ten-minute bedside sessions on the chart, and with the ward pharmacist drafted a one-page guide. Over the next three months the ward reported no further insulin near misses. Doing this taught me to look at the system first before assuming a knowledge gap."
- Why it works
- A non-clinical role evidenced through enabling others to practise safely, which the guidance accepts. Specific actions, collaboration and a measured outcome.
Notice what the weak versions share. They could be written by any nurse about any year. They repeat words from the standards ("culturally safe", "evidence-based", "continuous improvement") without showing them. There is no moment, no decision and no consequence. Use the list below to test your own drafts.
- Every sentence starts with "I always", "I ensure" or "I demonstrate".
- The example could have happened on any shift, anywhere.
- Phrases from the descriptors appear, but no actions you took.
- Nothing went wrong, nothing was hard and nothing changed afterwards.
- You would struggle to answer if your verifier asked "when was this?"
- The wording does not sound like the way you write or speak.
Privacy: one more reason to keep AI out
The audit guidance says you must protect the privacy of health consumers' personal information as set out in the Code of Conduct, keep people, colleagues and workplaces anonymous in your examples, and "only include information that is required for context".
Pasting real clinical details into a public AI tool creates a separate problem. The Office of the Privacy Commissioner's guidance on generative AI (first published June 2023) says not to input personal or confidential information into a generative AI tool unless it has been explicitly confirmed that the tool provider does not retain or disclose it. A rough note about a patient, typed into a chatbot to "turn into a reflection", may be both an authenticity problem and a privacy one. Your employer may also have its own policy on AI tools; check it before using any tool at work.
- Remove names, initials, dates of birth, NHI numbers and room or bed numbers.
- Describe the setting generally ("a medical ward", "a rural general practice") rather than naming it.
- Leave out unusual details that would identify someone in a small community.
- Keep drafts on your own device or in MyNC, not in shared or third-party tools.
Our health information privacy course covers de-identification in more depth if you want to strengthen this area.
Working with your verifier
Your verifier is a senior nurse, or your employer where no senior nurse works in your setting. The FAQ confirms that no second assessment is required: your self-assessment is verified (signed) by the senior nurse or employer. On the form, the verifier states that they have read your self-assessed evidence, confirming that it accurately reflects how you practise and that you meet the standards for your scope.
Not appropriate
Asking them to write your examples. Asking them to sign something they have not read. Choosing a verifier who has never worked with you just because they are available. Using examples involving them without checking that they agree with your account.
Helpful
Ask early. Give them the finished evidence, not a draft. Choose someone who has seen your practice. Invite them to point out anything they remember differently, and correct it. Talk through examples beforehand if it helps you recall detail.
Pre-submission checklist
Run through this before you sign. It is designed for the authenticity side of the audit; our audit-ready portfolio guide covers the full cross-authority checklist.
- Every PD entry has a date or period, an activity name, real hours and an honest pou link.
- Your PD total is at least 60 hours, all within the previous 36 months, and goes beyond mandatory or core employer training.
- You can produce something (certificate, email, roster, notes) for each PD entry if asked, even though certificates are not required.
- You have one example per pou: six for registered nurses, five for enrolled nurses.
- Each example describes a specific situation from the last three years, in the first person.
- Each example shows what you did, why, and what happened or changed.
- No AI tool wrote, rewrote, expanded or summarised any part of the evidence.
- Any tool you used (spell check, dictation) only handled words you wrote, and you checked with the Council if you were unsure.
- All examples are de-identified for people, colleagues and workplaces.
- Your verifier has read the final version and recognises the practice described.
- Your practice hours statement is accurate.
- You have read the declaration in full and every clause is true.
- You have saved a copy of everything you submitted, as MyNC does not save evidence for you.
How audits run, and if your evidence is questioned
When audits run, the Council's published process is as follows. Each year it audits five percent of practising nurses. If you are selected, you are emailed before your APC expires, and you upload your evidence through MyNC only when all of it is ready, because MyNC does not save evidence part-way through.
Nursing Council recertification audit page, October 2026. Evidence submission is currently paused during the strategic review.
Email notice before your APC expires. Some nurses are exempt, including those on a Council-approved PDRP or who passed a PDRP portfolio in the last three years, and those audited in the past three years.
Evidence uploaded through MyNC, with confirmation within three working days.
A Council auditor (a nurse trained in assessment) reviews your evidence. If it does not meet the requirements, you may be asked for additional evidence, with about one month to supply it.
If you disagree with the outcome, you can email to ask for further consideration and may make a written and/or oral submission.
Being asked for more information is a normal part of the process and is not, in itself, a finding against you. The Council's published audit material does not describe a separate procedure for evidence suspected of being AI-generated. What it does say is in the declaration: false or misleading information may lead to professional disciplinary action under the Act, and knowingly false declarations can be an offence.
If a concern about your honesty did reach that stage, it would be handled through the Council's conduct processes. Our guide to the Nursing Council complaint and investigation process explains how those work, and our overview of fitness to practise in New Zealand sets out the wider framework.
Our suggestion: do not sign until you have rewritten the evidence yourself from your own memory of events. If you have already submitted AI-assisted evidence, consider contacting the Council's audit team to correct it, and get advice first from your union (for many nurses, NZNO), your professional indemnity provider or a lawyer. Putting it right yourself is the kind of honesty and accountability the Code of Conduct expects.
Nurse practitioners have a separate recertification process. Their evidence includes a competence assessment completed by an authorised prescriber, at least 40 hours of professional development a year and at least 40 days of practice a year over the past three years, submitted through MyNC. The Council's nurse practitioner page does not currently mention an AI declaration, but the APC declaration still has to be true and correct, and the same honesty principles apply.
Frequently asked questions
Can I use spell check or a grammar tool on my audit evidence?
The Council has not said. Its guidance does not mention spelling or grammar tools. A basic spell check that corrects individual words you typed is unlikely to change who authored the evidence, but features that rewrite sentences or suggest new phrasing move towards text "created by artificial intelligence". Turn those features off, or ask the audit team before you use them.
Is the Nursing Council still running recertification audits in 2026?
The Council's audit page says it is undertaking a strategic review of continuing competence requirements for enrolled and registered nurses, and that nurses selected for audit are no longer required to provide audit evidence. It gives no end date. You must still apply for your APC in the usual way and make the continuing competence declaration.
Does the AI declaration apply to nurse practitioners?
The AI wording appears in the audit guidance and forms for enrolled and registered nurses. Nurse practitioners have a separate recertification process, and the Council's nurse practitioner page does not currently mention an AI declaration. Your APC declaration must still be true and correct, and the Code of Conduct's integrity value applies to every nurse.
Can a colleague or my verifier help me write my examples?
They can help you reflect. The Council encourages you to check in with nursing peers, mentors or senior nurses rather than using AI. The situation, the actions and the words must still be yours, because you declare that the evidence represents your own work and relates to your own practice.
How long should each pou example be?
There is no word limit. The Council's FAQ says most nurses can give enough detail in 500 words or fewer per pou. Specific detail matters more than length.
Can I reuse examples I wrote against the old competencies?
Not as they are. The FAQ says examples written for the previous competencies will not demonstrate how your practice meets the 2025 pou. You can describe the same real situation again, rewritten against the pou, and one example can support more than one pou.
Do I need certificates for my professional development hours?
No. The audit guidance and form say certificates are not required. You list the date or period, topic, hours and pou for each activity. Keeping certificates anyway makes your record easy to check and helps you avoid guessing.
What happens if the Council thinks my evidence is not authentic?
The published audit material says the Council may ask for additional evidence if requirements are not met, and the declaration warns that false or misleading information may lead to professional disciplinary action under the HPCA Act. Knowingly false declarations can also be an offence under section 172, with a fine of up to $10,000.
Primary sources
12 official documents
- Nursing Council of New Zealand: Recertification audits (Tātari kaute tiwhikete anō)
- Nursing Council of New Zealand: Recertification audit, guidance for enrolled and registered nurses (Version 2.0, October 2025)
- Nursing Council of New Zealand: FAQs, continuing competence and recertification audit requirements 2025
- Nursing Council of New Zealand: Registered nurse recertification audit form
- Nursing Council of New Zealand: Enrolled nurse recertification audit form
- Nursing Council of New Zealand: Continuing competence
- Nursing Council of New Zealand: Standards of competence for registered nurses (February 2025)
- Nursing Council of New Zealand: Standards of competence for enrolled nurses (February 2025)
- Nursing Council of New Zealand: Code of Conduct for nurses (June 2012; revision consulted on in 2026)
- Nursing Council of New Zealand: Nurse practitioner scope and recertification
- New Zealand Legislation: Health Practitioners Competence Assurance Act 2003
- Office of the Privacy Commissioner: Generative artificial intelligence (June 2023)