1 Background
The Electricity (Safety) Amendment Regulations 2025 (ESAR25) were published 13 October 2025 and the amendments come into effect 13 November 2025.

1.1 “Standards” have been modified by ESAR 2025 Schedule 2

In addition to long-overdue citing of Standards, the two schedules apply “modifications” to approximately eight installation and product standards via deletions and/or insertions of specific clauses. These include both major installation standards referred to by electrical workers such as AS/NZS 3000, and product standards such as AS/NZS 3112.

2 Questions

2.1 Question 1:
Traditionally, paper copies of critical documents like standards, procedures, and manuals would be amended by providing replacement pages for a bound copy, or instructing the user to hand-write modifications in the margins.
Given paper copies of standards are no longer commonplace, and all digital copies of the Standards with ESAR “modifications” are:
• Subject to copyright
• Copy protected (cannot be readily annotated or marked-up)
• Available with official amendments pre-applied (e.g. AS/NZS 3000:2018+A3)

What is the plan to ensure copies of the Installation Standards with the ESAR 2025 “modifications” pre-applied are readily available to Electrical Workers and other users, and/or allow users to apply these modifications themselves?

2.2 Question 2:
IANZ/NATA and equivalent accredited test houses are required to undertake product testing to the product Standards as written.
What work has occurred with IANZ/NATA to ensure that the “modifications” to product standards within ESAR 2025 will:
• Be enforced when testing product intended for the New Zealand market
• Be referred to on test certificates in a distinct manner from unmodified versions of the standards
• Not invalidate the testing for other jurisdictions using unmodified versions of the standards
• Be compatible with the remainder of the Standard, without introducing contradictions or unintended consequences

2.3 Question 3:
Given New Zealand is a small place that is subject to the same physics and international standards availability as the rest of the world, what is the basis for requiring bespoke New Zealand specific standards and rules?
Please provide any available analysis of the cost effectiveness and/or benefits of these bespoke requirements, particularly regarding concerns that it could:
• Unnecessarily result in "New Zealand only” or “not for New Zealand” equipment that increases cost and diminishes choice for New Zealanders
• Cause test certificates issued by New Zealand providers to not be accepted in other jurisdictions
• Require expensive and unnecessary double-testing

2.4 Question 4:
Given the choice to regulate prescribed electrical work and electrical products using Standards as a vehicle rather than using secondary legislation directly (e.g. ECPs and SWIs), why was the Standards development process insufficient to ensure the Standards were suitable without further modification?

Dear Rob Pope,

Thank you for your correspondence dated 11 December 2025.

I note that Section 15A Subsection 4 requires:

(4) The notice effecting the extension shall—

(a) specify the period of the extension; and

**(b) give the reasons for the extension; and**

(c) state that the person who made the request for the official information has the right, under section 28(3), to make a complaint to an Ombudsman about the extension; and

(d) contain such other information as is necessary.

Could you please clarify the reason behind the extension, and why the original extension was necessary especially given that the original requests were made to both organisations, so both organisations should have been able to begin work immediately.

Yours sincerely,

Aidan Thornton