The Retirement Commissioner has questioned the timing of a report into retirement policy and says research into whether KiwiSaver should exist would be a waste of taxpayers' money.

Diane Maxwell has been stung by criticism from two retirement policy proponents who say her 2016 review was disappointing and not based on evidence.

Maxwell undertook the three-yearly review of retirement policy last year and made 34 recommendations to the Government in December.

The Government has since responded with what it plans to act on.

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But Michael Chamberlain, an actuary and co-founder of KiwiSaver provider SuperLife and Michael Littlewood, a former co-director of Auckland University's Retirement Policy and Research Centre, say the review left out major elements.

"The findings were cloaked in a jokey, cartoon-like presentation on the website of the Commission for Financial Capability and amounted to 34 recommendations and observations with little to no supporting evidence for nearly all of them."

Maxwell said while the end result of her review did not look like a report it contained more data, analysis and submissions than previous reports.

While some stakeholders had found the form challenging she said feedback from the Government and private stakeholders had been universally positive.

The pair's report is called "The missing 2016 review - building trust for life beyond work". The report is 102 pages long, and includes nine key elements - none of which they say were addressed in the commissioner's review.

Those elements include a call for more household research on spending, a review of New Zealand Superannuation and KiwiSaver.

Chamberlain and Littlewood said 15 of the 34 recommendations were about KiwiSaver - but there was no supporting evidence to justify the continued existence of the scheme.

"Is KiwiSaver working? The 2016 Review didn't ask that question. Does New Zealand need KiwiSaver? If not, suggestions to 'strengthen' KiwiSaver are a policy cul-de-sac," they argue.

But Maxwell said she did not believe it would be a good use of taxpayers' money to invest time and resources asking if KiwiSaver should exist.

"Over 2.7 million Kiwis have over $40 billion in funds under management. It's here."

She also questioned the timing of the new report's release.

"I have some concerns about a piece of work that declares itself politically neutral but lands nine weeks out from an election."

Chamberlain and Littlewood said they chose election year because they were worried the Government's proposal to lift the age of entitlement for New Zealand Superannuation from 65 to 67 was politically motivated.

"We have decided to fill in some of the gaps because we worry that, in an election year, those gaps will be exploited by politicians wanting to attract attention to their parties' agendas - saying what it takes to get elected.

"New Zealand's political history shows that retirement income policies are particularly unsuited to political campaigns. We do not want New Zealand to re-learn that lesson."​

They say the three-yearly review of retirement income policy isn't working and must change - and a new Superannuation Accord should be put together to stop politicisation of retirement policy.

"None of these nine listed key elements, that we think should form the framework of a sustainable, flexible, inclusive, successful retirement income framework, rated a mention in the Retirement Commissioner's 2016 Review of Retirement Income Policies.

"They were missing in action."

Maxwell said her review followed clear terms of reference, providing an agreed starting point on what it would cover.

The review team had spoken to and heard from thousands of Kiwis as part of the project which had given it a far deeper understanding of the issues.

"The alternative is to sit in a room looking at spreadsheets, talking to people just like ourselves and drawing theoretical conclusions.

"Those conclusions are invariably based on our own agenda and world view and result in a form of blinkered, if earnest, elitism."