We can’t test yet, we’re going to make changes soon
This could be a good opportunity to introduce the concept of test-driven development (TDD) without the necessity to “write tests first”. But I think it can help illustrate why having tests is better when you are expecting to make changes because of the safety they provide.
“When we make those changes, wouldn’t it be great to have more confidence that the business logic didn’t break when adding a new technical capability?”
You shouldn’t have to refactor to test something
This seems like a reasonable statement and I sort of agree, in the sense that for existing production code, making a code change which only adds new tests yet also requires refactoring of existing functionality might feel a bit risky. As other commenters mentioned, starting with writing tests for new features or fixes might help prevent folks feeling like they are refactoring to test. Instead they’re refactoring and developing for the feature and the tests feel like they contribute to that feature as well.