28 January 2026
File Ref: 251173
Aidan Thornton
Via FYI
Dear Aidan
Thank you for your Official Information Act (Act) request received on 6 November 2025.
You requested:
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.
•
1 Background
The Electricity (Safety) Amendment Regulations 2025 (ESAR25) were published 13
October 2025 and the amendments come into effect 13 November 2025.
•
2 Questions
o
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?
o
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
PO Box 165, Wellington 6140
o
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
o
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?
On 11 December 2025, we extended the time limit for deciding on your request to 6
February 2025. Again, we apologise for the delay in communicating this decision.
Response:
Please find attached a table detailing WorkSafe’s response to the requested information.
WorkSafe consulted with the Ministry of Business, Innovation and Employment (MBIE) in
relation to some of the information requested and the preparation of the response to your
queries. I can confirm that the requests you sent to WorkSafe and MBIE were identical,
and that WorkSafe and MBIE agreed how the response would be divided between the two
agencies.
I understand that MBIE has already responded to the relevant aspects of your requests.
If you require further assistance, please contact
[email address]. Yours sincerely
Rob Pope
Head of Inspectorate
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