New Zealand, Australia and the United States
How are NZ Super, the Australian Age Pension and US Social Security different?
They are built on three different ideas. New Zealand Superannuation is paid on age and residence, and the criteria carry no income or assets test, so you can keep working and still get it. The Australian Age Pension is paid on age and residence too, but it is means tested against both your income and your assets. US Social Security is earned through work: you build credits by paying in, and no benefit needs more than 40 of them, which is ten years. So one asks where you lived, one asks where you lived and what you have, and one asks how long you paid in.
The one-line version of each
| What it is based on | Age | Is it means tested? | |
|---|---|---|---|
| NZ Superannuation | Age and years lived in New Zealand | 65 | No income or assets test in the criteria |
| Australian Age Pension | Age and residence, then what you have | 67 | Yes, an income test and an assets test |
| US Social Security | Work you paid tax on | 62 reduced, 67 in full | No, but you have to have earned it |
New Zealand Superannuation: you lived here
Section 7(1) of the New Zealand Superannuation and Retirement Income Act 2001 entitles a person to it once they "attain the age of 65 years". Section 8 adds the residence test: a number of years since age 20 that depends on your birth year, and five of them since you turned 50.
Work and Income list what else you need: to be a citizen, permanent resident or residence class visa holder, and to be ordinarily resident here when you apply.
Nothing in that list asks what you earn or own. Work and Income put the consequence plainly: "You can still get NZ Super while you're working", although a change of tax code may mean less reaches you after tax.
That makes it unusual. In New Zealand, a person with substantial savings and a person with none receive the same New Zealand Superannuation.
Australian Age Pension: you lived there, and it depends what you have
Australia starts from a similar place and then adds a second gate.
Services Australia set the age at 67, and the residence rule at ten years of Australian residence with five of them unbroken. So far, so similar.
Then: "You also need to meet: residence rules, an income test, an assets test." Both tests apply, and what you are paid reflects them.
This is the difference that matters most to anyone moving between the two countries. The same savings that make no difference at all to New Zealand Superannuation can reduce an Australian Age Pension. Several of the guides here exist because of that single fact.
US Social Security: you paid in
The United States works on a third principle again. You earn entitlement through work you paid Social Security tax on, measured in credits.
The Social Security Administration explains that you can earn "up to a maximum of four credits per year", and that "no one needs more than 40 credits for any Social Security benefit." Four a year, forty at most: ten years of covered work is the most anyone needs.
Age then decides the amount rather than the entitlement. You can start "as early as age 62", with the benefit reduced "by as much as 30%", or take it in full at the full retirement age, which is "67 for people who are born in 1960 or later".
There is no residence test of the New Zealand or Australian kind. What matters is whether you paid in, and for how long.
Why this shapes everything else
Once you see the three ideas, the cross-border questions in the rest of the library stop looking arbitrary.
A means tested pension has to ask what your foreign savings are worth, which is why Australia looks hard at a KiwiSaver balance. A residence based pension has to ask where you lived, which is why the Social Security Agreement between New Zealand and Australia exists at all. An earned pension has to ask what you paid in, which is why the United States counts quarters of coverage rather than years of residence.
What this guide does not tell you
It does not tell you what any of them pay, or how the rates change with living alone, having a partner, or moving overseas.
It also leaves alone the detail of Australia's income and assets tests, how a US benefit amount is worked out from an earnings record, tax on any of these payments, and the agreements between the countries. Each has its own guide or deserves one.
If you are likely to qualify in more than one country, the important follow-up is not how much each pays but how they treat each other, because receiving one can reduce another.
Sources
- New Zealand Superannuation and Retirement Income Act 2001, sections 7(1) and 8 (Age qualification; Residential qualification)
- Who can get NZ Super
- Who can get Age Pension
- Residence rules for Age Pension
- How do I earn Social Security credits and how many do I need to be eligible for benefits?
- At what age should I start receiving my Social Security retirement benefits?