No. If you do not have or do not wish to use your own TSL, you can hire out your vehicle using the Mighway/Tourism Holdings Transport license. Mighway handle any paperwork and registration you need to rent your vehicle commercially. As an owner, you will need to maintain private vehicle insurance and a Certificate of Fitness for your Vehicle.
As of July 1st 2017 Owners are able to operate under their own TSL, should they choose to.
Read more about TSLs here: https://www.mighway.com/nz/en/owners/gst-tsl