New Zealand made warm-and-dry standards binding on all 600,000-plus rentals from 2025-07-01, the primary evidence of compliance is a statement the landlord signs, and the ministry ran 1,100 proactive assessments in 2024

What is happening?

New Zealand requires every residential tenancy to meet five minimum standards for a warm and dry home: heating, insulation, ventilation, moisture ingress and drainage, and draught stopping. The standards were made under legislation passed in 2017 and are administered by the Ministry of Business, Innovation and Employment, which runs them through its Tenancy Services arm.

They arrived in stages. Boarding houses had to comply from 2021-07-01, Kāinga Ora and registered community housing providers from 2024-07-01, and all remaining private tenancies from 2025-07-01. Since that last date the standards bind more than 600,000 rental properties, which is every rental in the country.

The primary evidence that a property complies is a compliance statement the landlord signs. The national compliance figure the ministry cites is 90 percent, and it comes from a self-report survey of landlords. The national manager of the compliance and investigations team has said the survey broadly matches what the team sees in the field, and that the ministry itself holds no independent national estimate of the compliance rate. The stated position of the ministry is that it concentrates on responding to breaches rather than assessing every property.

The scale of independent checking is published. The compliance and investigations team ran 1,100 proactive on-site assessments in 2024, and more than 500 of them found at least one breach. In the first half of 2025 it ran about 900 assessments, of which about 270 found at least one breach. Set against a stock of more than 600,000 rentals, that is the whole of the proactive sample.

Figures released under the Official Information Act cover 2025-07 through the end of 2026-05. In closed cases over that window, breaches were identified across 3,699 rental properties. The same release records 463 complaints received, 213 formal investigations opened, 327 remediation cases carrying 634 breaches, 71 improvement notices covering 59 landlords, 5 infringement notices — all of them for missing paperwork rather than a physical defect — 9 referrals to the Tenancy Tribunal, and penalties and damages totalling about NZD 267,000. The most common breach types were gaps around walls and windows at 133, heating at 119, extractor fans at 107, and drainage at 99.

Where inspectors have looked hard at one sector, the picture has been different. A targeted sweep of 15 Auckland boarding houses in 2026-04, run with the city council and the fire service, found that 14 of the 15 failed at least one standard. In 2026-05 the Tenancy Tribunal ordered about NZD 44,000 in exemplary damages against an Auckland boarding house operator for failing to act on an improvement notice; the property housed 20 tenants, many of them international students. The maximum penalties available are NZD 50,000 for a landlord with six or more rentals and NZD 7,200 below that threshold.

Whose problem is this?

The body that sets the standard is the same body that decides how often anyone checks it. Nothing outside that body produces a second number to compare the first one against, so the published compliance rate has no independent reading beside it.

Where does this problem end?

The boundary here is not about how high the bar sits. It is about whether anybody can say, with a number that came from outside the landlord, how many properties clear it.

What is the state now, and what should it be?

Now

Needs a new measurementthe target state: the regulations describe the physical floor a property must reach, and that floor is public. What no source opened here supplies is a target for the verification side. There is no published target compliance rate, no published target for how many properties should be assessed in a year, no date by which the ministry says it will hold an estimate of its own, and no stated threshold at which the self-report figure would be treated as insufficient. The standards say what a house must be. Nothing opened here says how the country is meant to find out.

How big is it?

No representative measurement of compliance exists, so this quantity cannot be counted from the sources opened here. What exists is two instruments that bracket it and disagree widely: between about 60,000 and about 272,000 rental properties would fail at least one of the five standards, depending on which of the two is taken. The ends of that interval come from two different measuring instruments rather than from one sample.

The low end takes the self-report figure at face value: 604,884 renting households at the 2023 census, with the 10 percent of landlords who did not report compliance in the 2024 survey. The high end applies the breach rate the compliance and investigations team found in its own 2024 proactive assessments, where more than 500 of 1,100 properties had at least one breach. Those assessments are chosen rather than drawn at random, so the rate they produce is not a rate for the whole stock, and no source opened here performs that multiplication.

A signed statement records what the landlord says about the property rather than what an inspector found there. That is the whole distance between the two ends of this interval, and it is also the reason the interval cannot be narrowed from the sources opened here. The first half of 2025 gives a third figure, about 270 breaches in about 900 assessments, which sits between the two.

Neither end counts people. A rental property holds one household and sometimes many, and the boarding house that drew the 2026-05 tribunal order housed 20 tenants on its own.

Under what conditions does it arise?

1. Compliance is evidenced by the party being regulated. The compliance statement is signed by the landlord and is the first thing a tenant, and the ministry, has to go on. Nothing in the design of the scheme produces a second number that can be checked against the first one.

2. The national figure is a survey of the same party. The 90 percent rate is what landlords reported about themselves in 2024. In the same survey 95 percent of landlords knew the standards existed while 76 percent of tenants did, so the group least likely to know what the standards require is the group that would have to notice a breach and raise it.

3. Proactive assessment runs at about a thousand properties a year against a stock above 600,000. The 2024 total was 1,100 and the first half of 2025 was about 900. Those assessments find breaches at a high rate, between about 30 and about 45 percent, which is consistent with them being targeted rather than representative.

4. Enforcement is mostly complaint-driven, and complaints depend on the tenant. Across the eleven months to 2026-05 the ministry received 463 complaints and opened 213 investigations. A tenant who does not know the standards, or who expects to be looking for another place to live, does not generate one of those.

5. The instruments that follow a breach are graduated and slow. Improvement notices came to 71 over that window, infringement notices to 5, and tribunal referrals to 9. Every one of the 5 infringement notices was issued for missing paperwork rather than for a physical defect in the property.

6. Where inspectors look hard, the picture changes. A sweep of 15 Auckland boarding houses in 2026-04 found 14 of them failing at least one standard. That result and the 90 percent national figure are not reconciled by any source opened here.

What has been tried?

Two directions have been tried and a third has not. Coverage was widened until it reached every tenancy, and the wording of the floor was tightened. The measurement of whether the floor is met has stayed where it started, with the landlord signature at one end and about a thousand assessments a year at the other.

What was found?

Why is it still unsolved?

Enforcement absent — the warm-and-dry standard is binding on every rental in the country, and the apparatus that would show whether it is met was never built to the same size.

A rule becomes real at the point where somebody other than the regulated party can say whether it was followed. That point does not exist here at national scale. The compliance statement is signed by the landlord, the national rate is a survey of landlords, and the only independent measurement is a proactive assessment programme running at about a thousand properties a year against a stock above 600,000. Each of those three is a reasonable instrument on its own. Stacked, they mean that the answer to how many New Zealand rentals are warm and dry is an answer the landlords gave.

The second part is that the two measurements that do exist disagree and nothing reconciles them. The self-report figure is 90 percent compliant. The proactive assessments found at least one breach in more than 500 of 1,100 properties in 2024 and in about 270 of about 900 in the first half of 2025, and a targeted sweep of 15 boarding houses in 2026-04 found 14 failing. Targeted assessment is meant to run higher than the average, so the gap is not proof of anything by itself. It is also not resolvable, because there is no third number drawn from a representative sample to sit between them.

The third part is that the failure produces no event. Nothing is announced when a property quietly does not comply. The complaints arrive from tenants, and a 2024 survey put tenant awareness of the standards at 76 percent, so the detection channel narrows exactly where the standards are least known. Deadlines pass, coverage reaches 100 percent on paper, and each year the published compliance rate is calculated the same way it was the year before. A standard that nobody measures is a standard that exists only where someone happens to look.

What observation would mean it is solved?

Candidates — (a) the ministry publishes a national compliance estimate drawn from a representative sample of rentals rather than from landlord self-report (b) the breach rate found in independent on-site assessment falls over several consecutive years (c) the share of rentals subject to some form of independent check in a year rises to a level at which the sample can carry a national estimate.

(a) is the one that would actually change what is known. It is also the narrowest: an estimate is not a repair. A representative survey could report that a quarter of rentals fail a standard and nothing about any individual property would change. What it would end is the present condition, in which the number the country uses to describe itself was supplied by the party being measured.

(b) alone is the weakest of the three. The proactive assessment programme selects the properties it visits, so its breach rate moves when the selection method moves. A fall could mean fewer breaches or a wider net that pulls in more compliant properties. Without the selection rule published alongside the rate, the series cannot be read as a trend.

(c) alone counts visits. Coverage is not the same as detection, and detection is not the same as remediation. Over the eleven months to 2026-05 the enforcement instruments actually used were 71 improvement notices, 5 infringement notices and 9 tribunal referrals. A larger sample that ends in the same instruments would tell the country more and change the housing less. The three have to be read together, and (a) is the one that would let the other two be read at all.

What is it connected to?

Fills with researchrental affordability and security of tenure, energy hardship and winter heating cost, respiratory and other health outcomes associated with cold and damp housing, the enforcement design of building and tenancy regulation generally, and rental quality regimes in comparable jurisdictions. Relation type and evidence grade were not confirmed in this round.

What these sources do not say

• Why the national compliance figure rests on self-report. No source opened here carries a published rationale from the ministry for evidencing compliance this way, or any statement of what it would take to change it. The sources record the position and the numbers, not the reasoning behind the design.
• How the 3,699 figure relates to the 327 remediation cases. Both come from the same Official Information Act release covering 2025-07 to 2026-05, and no source opened here reconciles them or states whether they count the same events on different bases.
• How the proactive assessment sample is selected. Nothing opened here describes how the 1,100 properties assessed in 2024 were chosen. Without that rule the breach rate cannot be compared with the self-report figure in either direction.
• Whether the same gap applies to Kāinga Ora and registered community housing providers. They have been covered since 2024-07-01 and no source opened here reports how their compliance is evidenced or verified.
• The size and budget of the compliance and investigations team. No source opened here states its headcount or its funding, so the assessment total cannot be read against the resource behind it.
• What happened to the properties where breaches were found. No source opened here reports how many of the 3,699 properties were remediated, or how long remediation took.
• How many rentals are exempt. The standards carry exemptions, one of the private assessment figures is explicitly said to include exempt properties, and no source opened here gives the size of that group.
• What the tribunal remedy rate rests on. Two sources give 18 percent and 21 percent for the share of healthy homes cases where the tenant obtained full remedy, neither states its counting basis, and neither acknowledges the other.
• The regulation text itself. No version of the legislative instrument was read in this round; the official legislation site refused every automated request.

See the evidence

No primary legal instrument was read in full. The two Tenancy Services notices and the Tenancy Services enforcement page were opened directly and carry the commencement dates, the scope figure of more than 600,000 rentals, the proactive assessment totals and the maximum penalties. Everything about the enforcement record over 2025-07 to 2026-05 comes from one news organisation reporting figures obtained under the Official Information Act, and the same report carries the statement that no independent national compliance estimate is held. Where sources overlap they agree on the commencement dates and on the scope figure. Where they disagree the disagreement is left visible rather than resolved: the self-report rate of 90 percent sits against breach rates of about 45 percent in the 2024 proactive assessments, about 30 percent in the first half of 2025 and 14 of 15 in the 2026-04 boarding house sweep, with no source opened here reconciling them; the tribunal full-remedy rate is given as 18 percent by one source and 21 percent by another, with neither stating its counting basis. This is a Path A output (research-based definition), so observation_refs is empty and provenance_mode: press-derived.

People affected

Estimated range 60,488–272,198 As of 2023 census household count against 2024 compliance measures

Sensitivity This is not a sampling interval. Its two ends come from two different instruments — what landlords report about themselves, and what inspectors found in properties they chose to visit — and no representative measurement exists to sit between them, which is the subject of this document rather than a defect of this estimate. A third figure points the same way and lands inside the interval: about 270 breaches in about 900 proactive assessments in the first half of 2025, or about 30 percent. A targeted sweep of 15 Auckland boarding houses in 2026-04 found 14 failing, far above the high end, but 15 properties in one sector cannot be projected nationally. Pushing the other way: the household base includes properties that are exempt from one or more standards, and one private assessment figure is explicitly stated to include exempt properties, so both ends are inflated by an amount no opened source quantifies. The count is of rental properties and households, not of people. A property can hold one household or twenty tenants, so the number of residents affected is larger than either end by a factor this estimate cannot supply.

Regional breakdown No source opened here breaks compliance, complaints, proactive assessments or breaches down by region or territorial authority. The only geographic detail available is a single targeted sweep of 15 boarding houses in Auckland, which is a sector-specific sample rather than a regional measurement, and splitting the national figures by population would be apportionment rather than measurement.