Was Labour trying to get around electoral spending laws?

The Campaign for Change announced on 17 June:

“The Campaign for Change will channel the energy and passion of New Zealander’s who want to see a change of Government this election.” says Director Matt McCarten.

This non-partisan campaign is being created in order to get people engaged and involved. The disconnect between a million citizens and political participation is a threat to our democracy.

We now know this was a lie. McCarten set up Campaign for Change as a taxpayer funded staffer for Little. It was run by two Labour Party paid staff and two Labour Party officials. They recruited unpaid foreign workers for it under the guise of Labour Party fellowships. We also know that some of these foreign workers were being assigned to campaign for specific Labour candidates.

So why was this Labour Party campaign pretending to be independent of Labour?

Presumably as a way to get around the electoral laws that restrict how much you can spend on a campaign.

If Campaign for Change phones 100,000 people to persuade them to vote Labour, then that is invisible advertising. It is not like a billboard or pamphlet which you can see has an authorization statement.