A quick guide to ANZAC Day 2026

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We get plenty of calls at this time of year about ANZAC Day. This year there’s an added layer of confusion — because 25 April falls on a Saturday, Mondayisation rules apply. Here’s a quick guide to ANZAC Day 2026.

The basic rule

Under the Holidays Act 2003, when ANZAC Day falls on a Saturday, the public holiday falls on that date. However, for employees who do not normally work Saturdays, the observance of the holiday transfers to the following Monday.. For employees who wouldn’t normally work on a Saturday, the public holiday shifts to the following Monday (27 April).

An employee is only entitled to observe the public holiday on one day — not both.

2026 Mondayisation in practice

Bob works Saturdays but not Mondays. ANZAC Day is observed on Saturday 25 April. If Bob works that day, they’re entitled to time and a half, plus an alternative holiday. Monday 27 April is not a public holiday for Bob, so no public holiday entitlements apply.

Tash works Mondays but not Saturdays. Saturday 25 April is not otherwise a working day for them, so the public holiday transfers to Monday 27 April. If Monday would otherwise have been a working day and they don’t work it, they’re entitled to a paid day off. If they do work it, they’re entitled to time and a half plus an alternative holiday.

CeeCee is on a variable roster and has worked some Saturdays. Whether ANZAC Day is a public holiday for them on Saturday, or Monday, depends on whether Saturday would otherwise have been a working day. If they are regularly rostered on Saturdays, this may indicate that Saturday is an otherwise working day. A full assessment is still required against their work patterns, employment agreement, and roster history. This is where the otherwise working day test becomes important.

The ‘otherwise working day’ test

Whether an employee is entitled to public holiday pay — on the Saturday or the Monday — depends on whether that day would otherwise have been a working day for them. This isn’t always straightforward, particularly for staff on variable rosters or casual arrangements. You’ll need to look at their work patterns, their employment agreement, roster history, and the reasonable expectations of both parties. Our Otherwise Working Day guide steps through the full assessment process.

Closed over ANZAC Day?

If you’re closing and your team is taking leave, any public holidays that fall within that period must still be paid as public holidays. They can’t be deducted from an employee’s annual leave entitlement. This applies where the public holiday would otherwise have been a working day for the employee.

Public Holiday surcharges

For ANZAC Day and other Mondayised holidays, a practical approach to public holiday surcharges is recommended. While increased wage costs may arise across both the actual public holiday (e.g. Saturday, 25 April) and the Mondayised day, these costs are often shared rather than duplicated in full. In line with guidance from the Commerce Commission, any surcharge should reflect the genuine additional costs of operating on a public holiday, be reasonable and proportionate, and be clearly communicated to customers in advance.

In many cases, businesses choose to apply a surcharge on the actual calendar date of the public holiday. However, a surcharge may also be applied on other days where public holiday entitlements result in increased costs, provided there is a clear and justifiable basis for doing so. That said, from a practical and customer-relations perspective, applying a surcharge across both days can sometimes lead to customer dissatisfaction or confusion. For this reason, many businesses choose to limit the surcharge to one day only, unless the additional costs across both days can be clearly justified and communicated.

Alcohol sales on ANZAC Day — the rules have changed

One more thing worth noting for this ANZAC Day: the old restrictions on selling alcohol on restricted trading days no longer apply to on-licensed premises. The Sale and Supply of Alcohol (Sales on Anzac Day Morning, Good Friday, Easter Sunday, and Christmas Day) Amendment Act 2026 came into force on 3 April 2026. If you hold an on-licence, you can now sell alcohol under your normal licence conditions. You no longer need to limit service to by using the old “substantial meal” requirement. Any licence condition restricting alcohol sales on restricted trading days no longer applies.

Note that all other licence conditions still stand, including any Local Alcohol Plan (LAP) requirements. Your obligations under the Sale and Supply of Alcohol Act 2012 — around minors, intoxication, and responsible service — remain in full effect. The changes do not apply to off-licences; bottle shops and supermarkets remain restricted on ANZAC Day. Note that these remain restricted trading days under retail trading laws — this change only affects alcohol sales for on-licensed premises.

If you’re unsure how any of this applies to your team, call the Restaurant Association Helpline on 0800 737 827.

More information

What to do if your tax debt is simply too much to handle

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This article has been provided by Inland Revenue (IRD).

If you’ve missed a tax payment or two, Inland Revenue will usually let you pay it off over time. If you set up a reasonable payment plan and keep to it, no further penalties will be added to your debt. You can even set this up online in myIR, without needing to talk to anyone at Inland Revenue.

However, you’ll encounter difficulties when a tax bill is ignored for too long and penalties and interest get added. For example, leaving a $10,000 PAYE bill unpaid for a year could see the debt grow to more than $23,000. So what can you do when the debt has become too much to handle?

Here are three case studies from the hospitality sector, each involving tax debts and showing what can make a difference when tax debt gets out of control.

Case study 1: Making the necessary changes

A family-run enterprise with several businesses in the hospitality sector found itself in difficulty after the Director experienced serious health issues, meaning some GST and income tax payments were missed over a period of time, and the debt grew significantly.

Once other family members recognised the severity of the situation, they made changes to the leadership of the business and, through their accountant, began engaging with Inland Revenue. Taking into account the Director’s health circumstances, and the fact that current tax obligations were now being met, Inland Revenue agreed to cancel the penalties that had been applied — on the condition that a realistic plan was put in place to pay off the core debt and interest. The family was ultimately able to pay off the debts of some businesses in full, make a lump sum payment toward another, and set up instalment arrangements for the remainder.

Case study 2: Selling the business

A takeaway store had accumulated a large tax debt. When Inland Revenue made contact, the owner initially planned to pay it back, made some payments, and set up an instalment arrangement — but was ultimately unable to keep to it. Unfortunately liquidation proceedings were the likely next step, however, the Director asked for time to sell the business instead. With evidence of a sale and purchase agreement, a solicitor engaged, active listings, and at least one interested buyer, the liquidation proceedings were put on hold. While the sale didn’t raise enough to cover the full debt, Inland Revenue agreed to write off a significant portion rather than pursue it further, given there was no longer an ongoing risk to the tax base and further recovery was unlikely.

Case study 3: Continuing to trade without a viable plan

This case study has a difficult outcome as the owners clearly cared about their staff and their community, however, it’s a reminder that seeking advice early can make a significant difference to what options are available. A restaurant had accumulated a significant six-figure tax debt, a large portion of which was PAYE. Inland Revenue advised the Directors they should consider closing the business, but the owners were reluctant to let down their staff and the wider community. While they offered to pay the debt off over time, there was no realistic means of doing so within a reasonable timeframe. The business continued to trade for several months, during which the debt increased again. Ultimately the business was liquidated through proceedings by the Inland Revenue and there is a further possibility of debt being recovered from the owners’ personal assets.

The cases above show that outcomes vary widely depending on the circumstances — and crucially, on how early people engage with Inland Revenue. The final case study is a difficult one; and highlights how situations can become significantly harder for everyone over time. If you are concerned about your tax position, Inland Revenue encourage you to make contact with them early. If you are concerned about your tax position, Inland Revenue encourage you to make contact with them early — the more time there is to work through options, the better the outcome is likely to be.

Additional links:

We’re making sure hospitality’s voice is heard on fuel disruption

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The global fuel supply disruption flowing from the Middle East conflict is already hitting our hospitality businesses — and we’ve been working hard to make sure the impacts are being heard at a government level.

In early April, we ran a member snapshot survey to understand where things were at. Two thirds of respondents reported reduced customer numbers, nearly half reported reduced spend per customer, and over 60% were already seeing increased fuel and delivery costs. As we know, these pressures are landing on top of margins that are already too tight.

We’ve been providing our feedback to feedback – both the current impacts we are seeing, as well as feedback on the Fuel Response Plan. This is the framework that will prioritize fuel supply and guide how fuel is allocated if disruption deepens.

We are heavily dependent on fuel supply indirectly

While hospitality isn’t generally a heavy direct user of fuel, we’re deeply dependent on it indirectly. Every delivery that arrives at your back door, every supplier run, every staff member driving a shift — all of it relies on fuel flowing through the system. As we’ve already started to see, when that’s disrupted, we feel it immediately.

Our feedback makes the case that food supply chains — including the distributors, wholesalers, and specialty suppliers we all rely on — need to be protected within the government’s prioritisation framework. Food distribution needs to sit within those protected bands, and the definition needs to be broad enough to cover the full network of suppliers our industry depends on.

Of course, for hospitality workforce mobility is also key and we have raised this. Many of our team members rely on being able to get to work, particularly in regional areas and across shift-based rosters.

We’ll continue to keep you updated

We’re continuing to monitor the situation and staying engaged with government. If disruption escalates and prioritisation bands come into effect, we want to make sure hospitality is recognised not just as a business sector, but as an enabling part of the wider economy — one that supports tourism, employment, and community life right across the country.

We’ll keep you updated as things develop. In the meantime, if you’re experiencing significant impacts, keep records of cost increases, supplier changes, and shifts in customer behaviour — this kind of evidence strengthens the case we’re making on all our behalf and please do feel free to get in contact.

UPDATE:

On 11 May, 2026 the Government provided details of changes to the Fuel Response Plan. This aligns with the Association’s submission – signalling that, in a fuel disruption or shortage scenario (move to Phase 4), the Government wants the system to stay flexible enough that essential parts of the economy — including food distribution and hospitality supply chains — can keep operating. Read the Government Press release here.

More information:

Middle East conflict: what are the impacts we’re seeing now?

Middle East conflict: How Kiwi hospitality operators can mitigate rising costs

Middle East Conflict: what it could mean for hospitality

Upcoming EFTPOS network upgrade – attention needed

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Payments NZ, who operate the EFTPOS terminal network, require all Point of Sale (POS) terminals with a hardware specification of Payment Card Industry (PCI) 4.x to be upgraded by 30 April 2026, so you can continue to accept card payments on your terminal.

If you do not upgrade your terminal by this date, you will no longer be able to accept card payments.

What you need to do

To continue accepting card payments after 30 April 2026, you’ll need to upgrade your terminal.

You can find out what out the hardware specification of your terminal is by asking your EFTPOS terminal supplier, who can also advise you about upgrade options.

If you’re a Westpac customer, call 0800 888 066 and select option two between 8:30am and 5pm weekdays, email [email protected] or visit their website to explore their range of compliant terminals.

Middle East conflict: what are the impacts we’re seeing now?

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This week, we surveyed members across New Zealand to understand at this point how the Middle East conflict is impacting. The results are sobering.

The impact is widespread.

Of those who responded to the survey, just 6% reported no effect. For the rest, the pressure is coming from multiple directions.

More than two thirds of you (67%) are seeing reduced customer numbers and covers — the most commonly cited impact. Close behind, 62% are dealing with increased fuel and delivery costs, and 46% with higher food and beverage costs. Reduced spend per customer (44%) and increased cancellations or no-shows (39%) round out the picture.

When asked how much of this you attributed to the Middle East conflict specifically, the response was unambiguous. More than 75% said the conflict was either “mostly” or “entirely” responsible for the changes you’re experiencing.

Customer numbers are also tracking down compared to this time last year. Nearly 70% of you reported covers running either slightly or significantly lower than the same period in 2025 — with only 16% reporting improvement.

Looking ahead, rising food and beverage costs (86%), reduced customer demand (80%), and rising fuel and delivery costs (79%) are the top concerns. Nearly half of you — 47% — named business viability as a top concern.

On pricing, 80% said you were actively considering adjustments but hadn’t yet acted. Just 7% had already moved on pricing, while 12% had no plans to change.

Selected comments

“Here we go again. Yet another economic recovery false start. Another punch in the face for hospo. Mentally draining times for sure.”

“People are scared of what their money will no longer cover, and therefore luxuries like dining out is the first pleasure to go.”

“The uncertainty is very unsettling. We operate rurally, so people are already paying a lot more just to get to us — so I’m really reluctant to put prices up but realise we will have to.”

“Revenue is declining and costs are increasing — we’re being squeezed from both ends.”

“The thought of facing another challenging year on the back of so many is really hard to deal with. Our mental health will suffer and we worry about getting the business through another tough year.”

The theme running through so many of your responses is fatigue. We’ve navigated COVID, inflationary pressure, and dire economic environment in 2025, slow recovery — and now here’s another external shock, completely outside our control.

What you can do right now to mitigate impacts

There are no easy answers, but there are practical steps you can take to protect your margins and reduce your exposure. We’ve outlined seven strategies in detail — from rethinking your menu and tightening food waste, to managing energy costs and pivoting your marketing toward domestic diners.

Read: Middle East conflict — how Kiwi hospitality operators can mitigate rising costs

For general information on fuel updates the following links are useful: 

Easter Bill passes final reading – changes to be in place for Easter

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Key points at a glance:

  • The Sale and Supply of Alcohol Amendment Bill passed its third reading on 1 April 2026, with Royal Assent expected 2 April — meaning the new rules apply this Easter weekend
  • On-licence venues permitted to open on Good Friday, Easter Sunday, Anzac Day morning, and Christmas Day can now serve alcohol under normal licence conditions
  • The requirement to serve a “substantial meal” alongside alcohol on these days has been removed entirely
  • Venues can now also remain open past midnight on the eve of restricted days, within their normal permitted trading hours
  • Off-licences and supermarkets are not affected — existing restrictions on those premises remain

Easter weekend has long been one of the most confusing periods on the hospitality calendar — particularly because of the patchwork of different rules that apply to each day of the long weekend. With the passing of the Sale and Supplier of Alcohol (Sales on Anzac Day Morning, Good Friday, Easter Sunday, and Christmas Day) Amendment Bill tat confusion can be a thing of the past .

On 1 April 2026, Parliament passed the Bill on its third reading, with Royal Assent expected on Thursday 2 April. That means the new rules are in effect for this Easter weekend.

This is change that we welcome.

What’s changed

Until now, on-licence venues that were permitted to open on Good Friday, Easter Sunday, Anzac Day morning, and Christmas Day could only serve alcohol to guests who were “present on the premises to dine” — specifically, those who had ordered a “substantial meal.” That term was never defined in law, and guests weren’t even required to eat the meal, just purchase it.

The result was a situation that was often unworkable. As our Restaurant Association president Mike Egan describes it, the law was “a relic” that created daily friction with guests simply wanting a drink after a walk or a bike ride.

The new law removes the meal requirement entirely for on-licence premises. If your venue is permitted to open on these days, you can now serve alcohol under your normal licence conditions — no caveats, no meal thresholds, no grey areas.

It’s also worth noting an amendment from ACT MP Cameron Luxton that was adopted into the bill: venues can now remain open past midnight on the eve of these restricted days, operating within their normal permitted trading hours. No more last drinks at 11:59pm.

What hasn’t changed

This legislation is specifically targeted at on-licence premises. Off-licences and supermarkets remain subject to existing restrictions on these days. The overall framework of which days carry restrictions has not changed — this is about how on-licence venues operate on those days, not about expanding access more broadly.

The impact for Restaurants and Cafés

For most of our members — restaurants and cafés — the practical day-to-day impact may be more modest than for bars, since you were already able to serve alcohol alongside food. But the removal of the “substantial meal” requirement is still important and removing the confusion around operating on these restricted days is something we support. The rules are now consistent with every other weekend of the year, and that consistency has real value — for your staff, for our customers, and for the experience you’re offering.

Our view

We have long supported reform of Easter trading rules as they apply to hospitality. The previous legislation created confusion without providing benefit. What it did do was make life harder for operators, create unnecessary tension with customers, and make New Zealand hospitality look a little old-fashioned to international visitors.

The Bill was put forward by Labour MP Kieran McAnulty, and cross-party support that made it possible to pass the Bill.

One important note: many of your customers may not know the rules have changed. Given the legislation passed with such short notice before the long Easter weekend, there’s likely to be some public uncertainty about what’s now possible. We encourage you to communicate openly — on your social channels, your website, and at your venue — that you’re open and operating as normal. This is a good news for hospitality, and your customers will appreciate knowing they can come and enjoy your venue without the old complications.

More information:

Middle East conflict: How Kiwi hospitality operators can mitigate rising costs

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In our recent article on the Middle East conflict and its impact on hospitality, we outlined the pressures now bearing on hospitality — from rising fuel costs and disrupted shipping routes, to potential international visitor impacts. But while there are some things we can’t control, here are the key strategies to protect your margins right now.

1. Rethink your menu around cost-stable ingredients

Many operators are already committed to buying local. But even with a strong local focus there may be room to push further, particularly when it comes to freight-dependent specialty items.

With imported ingredients potentially becoming less predictable in both price and availability, now is a good moment to audit your menu.

  • Are there imported items that could be swapped for a New Zealand equivalent?
  • Are there seasonal local ingredients you’re not yet making the most of? Leaning further into domestic produce, proteins, and shorter supply chains significantly reduces your exposure to freight volatility.
  • Where you do continue to use imported items, make sure your team understands the cost pressures behind them — portion discipline and waste reduction can become more of a focus when everyone knows what’s at stake.

A tighter menu can help too. Fewer dishes can provide greater agility when costs shift.

2. Supplier relationships and contracts

While you’re feeling the pressure of rising costs or supply uncertainty, your suppliers are likely navigating the same landscape. But in volatile times, your supplier relationships can be one of your greatest assets.

A supplier who knows and values your business will go further for you than one who doesn’t. And the things that build that goodwill are often straightforward, including being a consistent and communicative customer.

It’s also worth having a broader awareness of your supply network — not to move away from valued suppliers, but so that if a specific product becomes unavailable, you’re not caught off guard. A good supplier will often help you think through those contingency options themselves.

3. Reduce food waste relentlessly

It may seem obvious, but waste is money walking out the door — and in a tight margin environment, it’s non-negotiable to address it. Tighten up your inventory management; track what’s being thrown away and why, and adjust ordering accordingly.

Cross-utilise ingredients across multiple dishes to reduce the risk of spoilage. Train your kitchen team on portioning consistency. Even modest improvements in waste reduction can meaningfully improve your bottom line without requiring any price increases.

Get some tips from our Kai Keepers food waste programme insights here.

4. Look hard at energy costs

Fuel prices are up across the board, and that flows through to your energy bills too. An energy audit — even a basic one — often reveals quick wins: inefficient equipment running outside peak hours, refrigeration that needs servicing, or lighting and heating that can be better managed.

If you haven’t already, explore whether your current energy contract is still competitive. In a rising energy cost environment, switching suppliers or locking in a fixed rate may offer useful protection.

RA partner, The Utility Company, will do the work for you – they’ll assess your usage and negotiate better rates on your behalf. Find out more.

5. Adjust pricing thoughtfully

Raising menu prices is uncomfortable, but when you are facing some cost rises yourself absorbing every increase isn’t sustainable.

Rather than across-the-board hikes, consider tiered pricing — protecting your most value-sensitive items while adjusting margins on dishes where diners have more tolerance. Introduce combination offers or lunch specials that deliver perceived value while managing your cost-per-cover. Be honest with your regulars: most people understand the current environment, and transparency builds trust.

6. Pivot marketing toward domestic diners

With international visitor numbers under pressure now is the time to double down on your domestic audience. Kiwi customers may be feeling some impacts themselves right now, but they are still eating out, and with outbound travel more expensive and uncertain, some may be inclined to spend closer to home.

Engage your existing customer base through social media, and create experiences that feel worth the trip — events, themed nights, local collaborations. Strong community connection and word-of-mouth are your most cost-effective marketing tools right now.

Looking further ahead, there is also a potential upside worth watching. Travelers from regions closer to the conflict — or those simply seeking stability and distance from uncertainty — may increasingly look to destinations like New Zealand. We’re geographically remote, politically stable, and an appealing choice for visitors who want to feel well away from global tensions. Be ready to capitalize if this benefit does materialise when those travellers do arrive.

7. Use technology to work smarter

Technology doesn’t have to mean a big capital outlay. Increasingly, accessible tools can help with inventory tracking, demand forecasting, rostering, and reducing the hidden costs of over-ordering or over-staffing. Operators who use data to make decisions are better placed to respond quickly when costs shift.

Global instability is not a new challenge for hospitality — this industry has weathered disruptions before and adapted. The operators who come through in the best shape won’t necessarily be the biggest or best-resourced, but those who move early, stay close to their numbers, and keep their teams and suppliers informed. There’s no single fix, but taken together, the steps outlined here can meaningfully reduce your exposure and keep your business on solid footing while the situation evolves.

Read more:

Middle East Conflict: what it could mean for hospitality

For general information on fuel updates the following links are useful: 

Health & Safety reform is coming

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or restaurant in mind. However, the proposals outlined in the Health and Safety at Work Amendment Bill, if passed, aim to reform New Zealand’s safety regulations by recognising small business, reducing compliance costs and focusing on critical risks. 

We support the development of a system that is easy to follow and low-cost for businesses, while retaining a high level of safety for employees and one that does not place disproportionate compliance burden on small hospitality businesses. 

A system that better fits small businesses

The Bill proposes a new category of “small PCBU” — any business with fewer than 20 workers for at least nine months of the year. This reform targets the many hospitality businesses that fall into this size grouping.

The Bill refocuses small PCBUs on managing “critical risks” — the hazards most likely to result in serious harm or death. In a hospitality setting, this could be things like LPG gas systems, deep fryers and hot oil, or significant manual handling risks. For everything else, you’ll still have baseline obligations around training, supervision, PPE and welfare facilities — but the reform aims to make the overall compliance load more proportionate.

This is important because we often receive feedback from our members that it can feel like you’re carrying a compliance burden that doesn’t reflect the actual risk profile of your business. This will change under the new proposals.

What we’re asking for

We support the Bill’s overall direction, and have made a submission on behalf of the industry. We’ve made a number of practical recommendations to make sure the reforms best meet the needs of hospitality businesses.

Two changes to note:

  • Approved Codes of Practice (ACOPs) with safe harbour protection. The Bill allows for the development of sector-specific codes of practice. The Minister will approve these, and following an approved code means you have met your compliance obligations for that risk. One of the common concerns we hear from members is that even when they’re doing everything right, they still feel exposed to liability. A safe harbour provision, backed by a hospitality-specific code, would give operators genuine confidence.
  • Clearer officer duties for owner-operators. If you’re the director of your company and the person working the floor every Saturday night, the Bill clarifies that your governance duties and your day-to-day worker duties are separate. This should reduce some of the personal legal anxiety that comes with wearing both hats.

We’ve also asked the Committee to ensure clarity around how casual, seasonal, and contractor workers count toward the 20-worker threshold — something especially relevant in hospitality, where staffing levels can shift significantly across the year.

What happens next

The Bill is currently before the Select Committee, and we’ll continue to engage as the reform process progresses. Our submission calls on the Committee to prioritise the development of a hospitality-specific ACOP — a practical, plain-language guide to managing critical risks in our sector. That’s something we’d be positioned to help shape, and we’ll keep you updated at the point that that work develops.

In the meantime, if you’re looking for practical health and safety guidance tailored to hospitality, our Health and Safety programme is a good place to start. It’s designed to translate your legal obligations into everyday, workable practices for you. Understanding the law in general terms is one thing, but knowing exactly what it means for your kitchen or front-of-house is another.

We’re here to help you navigate any changes. As always, reach out to the team if you have questions.

More information:

Keep the cash flowing – Westpac cashflow guide

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A guide to improving cash flow in your business

Where’s your cash going?

Cash flow is the money coming in and out of your business – having more cash on hand helps the business thrive and grow.

Healthy cash flow is vital to any successful business. When the cash is flowing, you’ll thrive. Run out of cash though, and you may struggle. Cash flow is a constant worry for owners of smallto-medium-sized businesses, and problems with cash flow can be the biggest obstacle for survival and growth. Improve your cash flow and your business will be in better shape – that’s why Westpac have created this guide to provide you with some tips and insights into successful cash flow management.

Read this handy business cashflow guide to provide you with some tips and insights into successful cashflow management. Plus, you can find more ways to improve your cashflow here on the Westpac website here.

More information

As a proud partner of the Restaurant Association of New Zealand, Westpac provide members with support and benefits to help you meet your financial goals. Plus, Restaurant Association of New Zealand members can also benefit from preferential Westpac merchant rates. Find out more here.

Submission on the Health and Safety at Work Amendment Bill

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March 2026

To the Education and Workforce Committee

Introduction

  1. The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to make a submission on the Health and Safety at Work Amendment Bill (the Bill).
  1. This submission is made on behalf of the Restaurant Association’s members, who are predominantly restaurant and café owners and operators across New Zealand. We are the representative body for more than 2,500 hospitality businesses, with more than 50,000 employees. Our membership spans the length and breadth of the country.
  1. The Restaurant Association is an employer organisation, representing specifically small PCBUs in the hospitality sector.
  1. Feedback we have gathered from our members directly informs this submission. We draw on that data throughout to ground our views in the actual experience of hospitality operators.
  1. The hospitality industry is characterised overwhelmingly by small businesses. The majority of our members employ 20 or fewer people, meaning the provisions directed at small PCBUs are directly and significantly relevant to our sector. We note that Statistics NZ data confirms 97% of all New Zealand businesses fall within the small business threshold proposed in this Bill — our members are the very businesses this reform is designed to assist.
  1. The Restaurant Association is supportive of the Bill’s direction. We support the development of a system that is easy to follow and low-cost for businesses, while retaining a high level of safety for employees and one that does not place disproportionate compliance burden on small hospitality businesses. We believe the Bill has genuine potential to address this — provided it is implemented with clear, sector-specific guidance and appropriate support for small business owners. The Restaurant Association considers that the success of these reforms will depend on the clarity, consistency, and practicality of implementation in practice.

Our Members’ experience with the current system

  1. Understanding obligations: Around 92% of members say they understand their health and safety obligations quite well or very well. However, those who reported difficulty specifically requested industry-specific templates or guides — indicating that understanding the law in general terms is not the same as knowing how to apply it in a hospitality context. In response to this feedback, the Restaurant Association has developed its own Health and Safety programme to provide hospitality operators with clear, practical guidance tailored to their operating environment. This reflects our members’ need for resources that translate legal obligations into workable, day-to-day practices.
  1. Compliance costs: Annual compliance costs vary widely across our membership, with most paying between $5,000 and $10,000 per year. Given that most hospitality businesses are micro- or small-businesses, even the lower range is significant. Members also spend between one and ten hours per week on health and safety compliance activity.
  1. Specific frustrations with the current system include:
    • The “reasonably practicable” standard, which members often perceive as open-ended and exposing them to significant liability regardless of the reasonableness of their actions
    • Reporting and logging requirements that are time-consuming and disproportionate for small operators
    • Inconsistent interpretation of compliance requirements by different certifiers
    • A perceived imbalance in accountability, with owners bearing significant legal exposure even where employee or customer behaviour contributed to an incident
  1. Sources of guidance: When asked where they turn for health and safety information, our members ranked their sources in the following order: (1) industry associations, (2) third parties authorised by WorkSafe, (3) law or regulations, guidance, and health and safety advisors jointly, (4) word of mouth, and (5) WorkSafe directly. Only 15% had directly queried WorkSafe for guidance — suggesting the majority of the sector navigates obligations without direct regulator support.
  1. System objectives: When asked whether the system balances risks with costs, 75% of members say “probably no” or “definitely no”. When asked whether it is clear, 56% said “probably no” or “definitely no”. These results reflect genuine concern about both the proportionality and the clarity of the current framework for our sector.

Part One: The Critical Risk framework and small PCBUs

  1. The Bill introduces a new category of “small PCBU” — a business or undertaking with fewer than 20 workers for at least nine of the preceding 12 months — and requires small PCBUs to focus their primary risk management duties on “critical risks”, while continuing to meet baseline worker welfare obligations (information, training, supervision, PPE, and welfare facilities such as first aid and washing facilities), and remaining subject to the overarching duty to ensure health and safety so far as is reasonably practicable.
  1. The Restaurant Association supports this reform.
  1. Some members say that the current system feels in practice as though a small café employing eight people has the same compliance expectations as a higher risk business. Members report that compliance expectations can feel overly complex, even if the legal standard is technically flexible. Members report a perception that regulators apply similar documentation or process expectations across very different business sizes.
  1. In addition, small businesses can misinterpret what “reasonably practicable” means for them, and may over-comply as a result, with some members reporting reliance on external consultants to provide reassurance on compliance (which comes at a cost to the business).
  1. We note the Bill’s definition of “critical risk” captures: (a) hazards already governed by high-risk regulatory regimes listed in Schedule 1A; and (b) any other hazard likely to result in death, a notifiable injury, illness or incident, or an occupational disease listed in the Accident Compensation Act 2001. In a hospitality context, this would typically capture higher-consequence hazards such as LPG gas systems, deep fryer and hot oil operations where there is potential for serious harm, and manual handling risks capable of causing significant injury — all of which our members already take seriously and manage actively.
  1. However, we have two concerns about implementation:
  2. The “worker” definition and the small PCBU threshold: We note that the definition of “worker” in the HSWA is intentionally broad, and includes not only employees but also contractors, subcontractors, and their employees. While this definition is well established, its interaction with the proposed 20-worker threshold for small PCBUs may create uncertainty in practice. Hospitality businesses may rely on a mix of permanent staff, casual workers, contractors for maintenance, and labour hire arrangements, often varying seasonally. It may not be clear in all cases how these different categories of workers should be counted toward the threshold. We ask the Committee to consider whether further clarity or guidance is needed on how the threshold is to be applied in these common scenarios. We also note the Bill clarifies that even for small PCBUs, the general duty to ensure health and safety “so far as is reasonably practicable” is not removed. This creates an important interaction between the overarching duty and the more specific focus on critical risks. We ask that the Bill and accompanying guidance provide sufficient clarity on how these duties are intended to operate together in practice, so that small business owner-operators can make confident, informed decisions about their obligations.
  3. Identifying critical risks in practice: Small PCBUs will need to assess which hazards in their workplace meet the “critical risk” threshold. Hospitality operators are generally very familiar with the hazards in their workplaces — such as hot surfaces, sharp knives, and slips and falls — and actively manage them. However, it may not always be clear how to determine which of these hazards are “likely to result in” a notifiable injury or death, as opposed to those that are common but lower consequence. This creates a practical “grey zone” where businesses must make judgement calls without clear benchmarks. We ask that the Committee to seek assurance that accompanying regulations provide clear, practical guidance on how this assessment is to be made, and that WorkSafe develops hospitality-sector-specific guidance as a priority following enactment
  4. Part Two: Approved Codes of Practice
  5. The Restaurant Association strongly supports both of these changes.
  6. Our members consistently identify industry associations as their primary source of health and safety guidance — ahead of WorkSafe, legal advice, and general regulatory guidance. This reflects the reality that industry bodies understand the day-to-day operating environment of their members. Our experience in developing sector-specific guidance for our members demonstrates the value of practical, industry-informed resources, and highlights the role that an ACOP could play in providing consistent, authoritative guidance across the sector.
  1. We consider that there is a strong case for the development of a hospitality-specific ACOP following the Bill’s enactment. Such an ACOP could provide practical, plain-language guidance on the critical risks most relevant to our sector in a form that owner-operators can readily understand and apply. It would help address the current situation in which our members piece together guidance from multiple sources. A hospitality ACOP would also play a critical role in providing clarity on how “critical risk” should be identified and managed in our sector.
  1. The Restaurant Association would be keen to engage with WorkSafe and other stakeholders on the development of such guidance, recognising the importance of ensuring that any ACOP reflects the practical realities of hospitality businesses.
  1. The safe harbour provision directly addresses our members’ most significant concern with the current system: the application of the “reasonably practicable” standard, which many members experience as open-ended and creating disproportionate legal exposure even for businesses that are acting responsibly. As one member put it in consultation from 2024: “If something goes to court, a prosecutor simply needs to establish that one more practicable and reasonable step could have been taken and the defendant will be found guilty.” A safe harbour linked to compliance with a sector-specific ACOP would give small business owners the confidence to focus on genuine hazard management rather than defensive over-compliance.
  2. We note that only the two most recently approved ACOPs (the Ports ACOP 2024 and the Forestry ACOP 2025) will carry safe harbour status on commencement. All other existing ACOPs will need to be reviewed and reapproved before achieving safe harbour status. We ask the Committee to consider whether the legislation should include a clear timeframe or priority programme for reviewing existing ACOPs, and for developing new ones in sectors — like hospitality — where no sector-specific ACOP currently exists.
  3. Part Three: Officer due diligence
  4. The Bill amends section 44 of the HSWA to clarify that an officer’s due diligence duties are governance duties only, confined to the listed due diligence steps in the Act and not extending to other roles the officer may also perform as a worker within the same organisation.
  5. The Restaurant Association supports this clarification. In the hospitality industry, the vast majority of businesses are owner-operated: the person who is legally the director of a company is also the person who opens the restaurant each morning, supervises the kitchen, and works the floor on busy nights. While the distinction between governance and operational duties exists in the legislation, our members report that applying this distinction in practice can be unclear.
  6. Clarifying that officer duties are governance duties — and that day-to-day operational responsibilities are managed separately as a worker — is a practical and sensible change that will help owner-operators understand their roles and reduce anxiety about their personal legal exposure.
  7. We ask the Committee to consider whether further guidance may be beneficial specifically for small business owner-operators explaining how this distinction applies in practice in their context.
  8. Part Four: WorkSafe’s functions
  9. The Bill amends WorkSafe’s statutory functions to prioritise providing guidance, advice and information on compliance with critical risks, and to refocus the regulator’s activities accordingly.
  10. Our members’ experience of WorkSafe has been mixed. When asked whether they would describe their interactions with the regulator as useful, reasonable and timely, responses were evenly split — half said yes, half said no. Only 15% of members had directly queried WorkSafe for guidance on their obligations, suggesting there may be an opportunity to strengthen engagement with the small business community in our sector.
  11. We support refocusing WorkSafe’s functions toward guidance and education. We note that the effectiveness of this Bill will depend in large part on WorkSafe’s capacity to deliver practical, sector-specific support — not just general information. This will be particularly important under a critical risk framework, where businesses will rely more heavily on guidance to identify and prioritise risks appropriately. Ensuring that support is accessible and relevant to smaller, lower-risk sectors such as hospitality will be key to the success of the reforms.
  12. Part Five: Overlapping regulatory requirements
  13. The Bill introduces a provision confirming that where a PCBU complies with equivalent risk management requirements under another enactment, they will be taken to have complied with the corresponding duty under the HSWA.
  14. We support this change in principle. Hospitality businesses operate under a range of regulatory frameworks — including the Food Act 2014, building regulations, and fire safety requirements — and the overlap and occasional inconsistency between these regimes and the HSWA has been a source of confusion and duplicate compliance cost for our members.
  15. We encourage the Government’s implementation plan to include clear, practical guidance on how the HSWA interacts with other regulatory regimes relevant to hospitality businesses. In particular, guidance should help operators understand how to assess when compliance with requirements under regimes such as food safety, building, or fire regulations may also satisfy corresponding HSWA duties. This will help reduce duplication, improve confidence, and support more efficient compliance in practice.

Summary of Recommendations

  • The Restaurant Association asks the Select Committee to:
  1. Support the critical risk framework for small PCBUs as a meaningful and proportionate reform for small hospitality businesses.
  2. Clarify how the “worker” count for the small PCBU threshold applies to casual, seasonal, contractor and labour-hire workers commonly used in hospitality.
  3. Seek assurance that the Bill clearly communicates that the general duty of care is not removed for small PCBUs, but that the scope of specific duties is limited to critical risks, so owner-operators have certainty rather than residual anxiety.
  4. Support the ACOP reforms, including the safe harbour provision and the ability for industry bodies to develop sector ACOPs.
  5. Consider whether there should be a clear approach or prioritisation for reviewing existing ACOPs and developing new ACOPs in sectors, like hospitality, where none currently exist.
  6. Support WorkSafe’s implementation plan including sector-specific guidance for hospitality as a priority.
  7. Develop practical guidance on officer duties as they apply to small business owner-operators who occupy both governance and operational roles simultaneously.

About the Restaurant Association of New Zealand

The mission of the Restaurant Association of New Zealand is to be the link between good food and good business so that our Members’ restaurants and cafés can succeed. Since 1972, the Association has worked to offer advice, help and assistance in every facet of the hospitality industry. We are the representative body for more than 2,500 hospitality businesses, with Members covering the length and breadth of the country.

More submissions by the Restaurant Association can be accessed here.

Alcohol law reform Bill introduced

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At a glance:

  • New Bill introduced to modernise alcohol laws and reduce compliance burden
  • More certainty for licence renewals, even where Local Alcohol Policies (LAP’s) change
  • More targeted, locally focused objection process
  • New pathway for some restaurants to hold both on- and off-licences
  • Zero-alcohol products formally recognised in licensing requirements
  • Further detail to come through regulations and select committee process

The Government has introduced the Sale and Supply of Alcohol (Improving Alcohol Regulation) Amendment Bill, signalling a significant step toward modernising New Zealand’s alcohol regulatory framework.

For hospitality businesses, cafés and restaurants, the Bill is largely positive. It reflects many of the practical challenges our members have consistently raised, including the need for more certainty, less red tape, and rules that better reflect how hospitality businesses actually operate.

Importantly, many of the changes align closely with the priorities we put forward in our Hospitality Summit recommendations — particularly around reducing compliance burden, improving licensing processes, and ensuring regulation reflects real-world operations .

What’s changing

A number of the proposed changes will have practical, day-to-day benefits for hospitality businesses.

For some restaurants, there is a notable new opportunity. The Bill introduces a pathway for venues that already hold an on-licence and operate a genuine retail component (such as deli-style or takeaway food offerings) to also apply for an off-licence. This reflects the increasingly blended nature of hospitality and retail, and could open up new revenue streams for some operators.

Another welcome update is the recognition of zero-alcohol products. Venues will be able to meet licensing requirements by offering zero-alcohol options, rather than only low-alcohol products. This better aligns with customer demand and addresses a long-standing issue raised by the sector .

The Bill also makes changes to the objections process. Objections will be more clearly focused on those with a genuine local connection, and applicants will have a formal right of reply. This is intended to make the process more balanced and reduce unnecessary delays, while still ensuring community views are heard where they are directly relevant.

There are also changes aimed at improving consistency in licensing decisions over time. While Local Alcohol Policies will continue to play a role, the Bill provides more clarity around how they are applied at renewal, helping to create a more stable and predictable operating environment.

Finally, the Bill introduces a more flexible framework for special licences and trading during significant televised events. While the overall direction is positive, much of the detail will be set out in future regulations.

Alignment with our sector priorities

These changes are consistent with what we have been advocating for.

At the Hospitality Summit’s in 2024 and 2026, members highlighted the burden and inconsistency of current licensing processes, including the need for clearer, more proportionate rules and better functioning District Licensing Committees.

Recommendations included improving the relevance of objections, streamlining processes, and ensuring licensing settings reflect how businesses actually operate. There was also clear feedback that alcohol regulations have not kept pace with consumer behaviour — particularly in relation to zero-alcohol products .

This Bill responds to many of those concerns and represents a step toward a more practical, business-aware system.

What to watch

While the direction of travel is positive, there are some important points to keep in mind.

Not all restaurants will automatically benefit from the new off-licence pathway. Eligibility will depend on how the “retail component” is interpreted in practice, and applications will still need to go through the licensing process.

Local Alcohol Policies will also continue to influence licence conditions, even if they can no longer prevent renewal outright.

In addition, several aspects of the reform — particularly around special licences and significant events — will be determined through regulations.

What happens next

The Bill has now been introduced to Parliament and will go through the legislative process, including a select committee stage.

This will provide an important opportunity for industry input. We will be engaging in the process and advocating for practical, workable settings that reflect how cafés and restaurants operate day-to-day.

If enacted, some changes could come into force relatively quickly, while others will depend on the development of supporting regulations.

Overall, this is a constructive and welcome step forward.

The Bill reflects many of the priorities identified by the hospitality sector and signals a move toward a more balanced and practical regulatory framework. While there is still work to be done, particularly through the select committee process, the direction is positive.

We will continue to keep members updated as the Bill progresses and will be seeking your input as part of our advocacy.

Further information:

Hospitality Summit 2026: turning industry voice into action

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The Hospitality Summit 2026, held on 12 March brought our industry into the heart of Parliament — creating a direct line between hospitality businesses and the people shaping the policies that affect them.

Delivered by the Restaurant Association, in partnership with Hospitality New Zealand, the Summit is built on the idea that real progress happens when industry and Government sit at the same table, focused on solutions.

What is Hospitality Summit?

The Hospitality Summit is a working forum. We bring together 55 operators from across the country, alongside Ministers, officials, and agencies, to talk openly about what’s happening on the ground — what’s working, what’s not, and what needs to shift. The discussion focuses on solution.

It’s also about recognising the role hospitality plays, keeping the country humming, shaping the vibrancy of our communities and forming a core part of New Zealand’s identity.

That role is increasingly recognised at a Government level — not just as part of tourism, but as a sector with real further potential to drive growth, jobs, and regional development.

Building momentum from the first Summit

When we held the inaugural Hospitality Summit in 2024, the goal was to move beyond talking about issues, and into working through them together – industry and Government.

That approach has delivered.

From 64 recommendation from the first Summit, more than 20 are now either complete or well progressed. That includes movement on long-standing pressure points like regulation, alcohol licensing, Easter trading, and Holidays Act reform — as well as new initiatives like the hospitality data portal and sector-specific wellbeing resources.

We’ve also seen long-advocated opportunities gain traction — including the arrival of Michelin to New Zealand, which sends a strong signal internationally about the quality of our food and hospitality offering.

None of this has happened in isolation. Much of this progress “gathered pace from the engagement in the room” — from operators sharing real experiences, and from a more coordinated partnership with Government.

Grounded in the reality of running a business

The strength of the Summit comes from who is in the room. Operators who are navigating the day-to-day realities of running a hospitality business — cost pressures, compliance, staffing, and shifting demand. People who understand where the friction points are, and where change would make a tangible difference.

Those perspectives are important – they ensure that discussions stay practical, and that the focus remains on removing barriers, unlocking growth, and creating an environment where businesses can succeed.

Partnership that drives progress

A defining feature of the Summit is the level of engagement from Government.

Ministers, MPs, and officials are part of the conversation — hearing directly from operators and working through the issues alongside us.

We also want to acknowledge the Minister for Tourism and Hospitality, Louise Upston, for her support in bringing the Summit together and for her ongoing commitment to engaging directly with the sector. That support has been instrumental in creating the space for these conversations to happen — and, importantly, for them to translate into action.

That support is critical. It creates a clearer pathway from problem to solution, and it’s helping to build momentum behind changes that have been needed for some time.

We are seeing a shared commitment to backing the sector — recognising that a stronger hospitality industry contributes directly to a stronger tourism offering, more vibrant communities, and a more resilient economy.

Where this leads

The Summit itself is just one part of the process.

What comes out of those discussions is captured and now shaped into a set of recommendations that we take forward as part of our advocacy. From there, the focus remains on delivery — continuing to work with Government to progress changes and track outcomes.

As we said on the day, what happens in that room has real consequences. And increasingly, we’re seeing those consequences play out in policy and progress.

Continuing the work

The Hospitality Summit is now an established part of how we represent hospitality at a national level.

It gives the sector a clear, collective voice — and a direct role in shaping the settings that will support its future.

And as that partnership with Government continues to strengthen, so too does the opportunity to build momentum — and deliver the kind of change the industry has been calling for.

More information: