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2019 Insulation Minimum Requirements: are you compliant?

22 January 2018

Photo: Wellington Houses by Kate Alderton

From 1 July 2019, it will be compulsory for all rental properties to meet the new minimum insulation requirements. All landlords should check that the insulation at their properties meets the standards and take action if necessary before the new requirements become compulsory.

From 1 July 2019 ceiling and underfloor insulation became compulsory in all rental homes. The Healthy Homes Insulation Standard increases the minimum standard for existing insulation. Read more here

Why has the government introduced new insulation requirements?

In 2015, the New Zealand Government introduced important reforms to the Residential Tenancies Act which require all landlords to ensure that their rental properties meet minimum insulation requirements. The changes were in response to concerns that many rental properties did not provide adequately safe, warm, or dry accommodation, particularly for lower income tenants.

The initiative, run by Tenancy Services, is called Warmer, Drier, Safer Homes.

Private landlords have been afforded a grace period until 1 July 2019 to meet the insulation requirements of underfloor and ceiling insulation.

What are the new requirements?

Right now

  • All new tenancy agreements must include an insulation statement.
  • If you install or replace insulation at a rental property, then it must meet the required standard.
  • Installation or repair of insulation products, such as reflective foil, that are electrically conductive is banned.
  • Social housing where tenants pay Income Related Rent must have underfloor and ceiling insulation that meets the required standards, provided it can be practically installed.

By 1 July 2019

  • All rental properties, including private rentals, must have underfloor and ceiling insulation that meets the required standard where it can be practically installed.

What happens if I don’t comply?
Failure to meet the insulation requirements is an unlawful act under the Residential Tenancies Act. Landlords may face fines of up to $4,000 for failure to comply.

The Ministry of Business, Innovation and Employment has a Tenancy Compliance and Investigations Team that investigate and enforce the law against landlords in breach of their obligations, including meeting the insulation requirements.

What are the required standards? Do I need to upgrade or install new insulation?

Use our flowchart to see whether you need to take action to upgrade or install new insulation.

Pro Tip: If you’re unsure whether your insulation meets the requirements, you should consult a qualified, professional insulation installer or inspector.

Note: consider ceiling and underfloor insulation separately. You should go through the flowchart twice: once for ceiling insulation, and then again for underfloor insulation.

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Watch this video from EECA Energywise to learn more about the insulation requirements

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When is insulation not in reasonable condition?

There is no strict or particular criteria for whether insulation is in a ‘reasonable condition’. However, you should consider the following factors:

  • Effectiveness - whether the insulation is fully effective in insulating the house.
  • The 4 D’s - the extent of any dampness, damage, degradation, or displacement of the insulation, including problems such as rips, tears, excessive settlement or compression, animal nests, mould, contamination, entrance holes for animals.
  • Gaps - whether there are any gaps in the insulation, other than gaps necessary for the function of the premises and the supply of services (e.g. water pipes).
  • Ancillary Material - condition or absence of material ancillary to the insulation (e.g. strapping or staples).

Consult the Insulation Requirements Guide and other resources from Tenancy Services for more information on whether insulation is in reasonable condition.

Repair or Installation of Foil Insulation is Banned

DANGER WARNING: Foil insulation poses a serious danger to your safety as it may conduct electricity from live wires. You should turn off mains power at your premises before inspecting foil insulation and/or consult a qualified professional insulation expert.

Due to the danger posed by foil insulation, installation or repair of it is now banned. This means that landlords are now prohibited from:

  • Installing new Foil Insulation - landlords cannot install new foil insulation.
  • Replacing or Repairing Foil Insulation - landlords cannot repair foil insulation that does not meet the new requirements - if the foil insulation is not in reasonable condition and does not have a high enough R-value, then it must not be repaired or replaced with foil insulation. It must be replaced with non-foil insulation.

You may only continue to use foil insulation if it was installed before 1 July 2016 and it is in reasonable condition and meets the R-value requirements.

Read more from Tenancy Services about the ban on foil insulation.

Key Resources to Learn More about the Insulation Requirements

Exceptions to Mandatory Insulation

There are 5 main exceptions where a property may be exempt from having to meet the ceiling and underfloor insulation requirements:

1. Underfloor or Ceiling Space Unsafe or Impracticable to Access

This exception applies to areas of homes where it would be unsafe or impracticable to access those areas due to limited access, their design, potential for substantial damage, or healthy and safety reasons. The area must be unsafe or impracticable for a professional insulation installer, not just a landlord or other unqualified person.

There are 3 common situations where this exception may apply:

  • Substantial Building Work or Damage Required - When an experienced professional insulation installer could not access the area without causing substantial damage to the property or substantial building work being required.
  • Health and Safety Risk - When an experienced professional insulation installer could not install insulation in a particular areas without creating a risk to the health and safety of any person. The risk must be greater than that usually considered acceptable for professional installers. This is usually where installation would pose a significant risk to the safety or health of the installer.
  • Installation Impracticable - When it is simply not reasonably practicable to install insulation in a particular area. For example, because there is not sufficient space between the ceiling and the roof.

This exception applies to particular areas of every rental property. So, if it would be unsafe or impracticable to install insulation for one room, insulation must still be installed in all other rooms where it is safe and practicable to do so.

No Exception: When there is no current access point for ceiling or underfloor
Even if there is no existing access point for a ceiling or underfloor, the landlord is expected to create such an access point in order to conduct the necessary insulation work, provided that it does not require significant building work.

2. Underfloor or Ceiling Spaces which are directly below or above habitable spaces

It will commonly be impracticable to install insulation in areas of ceiling or underfloor which are directly above or below habitable spaces.

Some common or important examples are:

Inaccessible Roof Spaces
Some ceilings and roofs have no way to access or insulate them without removing and replacing the existing ceiling or roof - this includes:

  • Skillion ceilings
  • Very low-pitched roofs
  • Bitumen membrane skillion roofs
  • Lean-to skillion roofs

If at any point the roof or ceiling is replaced, making any cavity accessible, then work must be done to ensure the premises meets the insulation requirements.

Inaccessible Underfloor Spaces
Some underfloor spaces have no means of access meaning that installation of insulation is not possible - this includes:

  • Areas with concrete slab floors
  • Floors suspended directly above habitable spaces of neighbouring units
  • Areas of floors that are too low to the ground for a professional installer to do the required work

If at any point such areas do become accessible for a professional installer, the necessary insulation work must be done at that point.

Low Roof Clearance
If part of a roof is too low to install insulation that meets the requirements, then a less thick insulation product may be used in those low-clearance areas.

Remember: Insulation must keep a distance of at least 25mm from the roof underlay in all parts of the ceiling-roof area.

Apartments and Units
Insulation does not need to be installed where the habitable parts of a unit are directly above or below the ceiling or floor of another unit.

Installation of insulation in such circumstances would likely require significant building work, meaning it is a matter for the Body Corporate.

Outbuildings and Garages
Outbuildings such as garages or sheds that are separate from the living areas of a property do not need to meet the insulation requirements. If, however, part of an outbuilding adjoins a habitable space, then that part must meet the insulation requirements. For example, if the roof of the garage is directly below the floor of a habitable space.

No Exception: When there is no current access point for ceiling or underfloor
Even if there is no existing access point for a ceiling or underfloor, the landlord is expected to create such an access point in order to conduct the necessary insulation work, provided that it does not require significant building work.

Habitable Spaces outside main premises
Any space, building or structure that is not part of the main premises but which is consistently used as a habitable space must meet the insulation requirements. This includes, studios, flats, caravans, or sleepouts.

3. Property meets particular insulation requirements at time of building, as approved by local council

In some very limited circumstances, a property may comply with particular insulation requirements specific to that property at the time of its construction. When these requirements do not meet the minimum R-values, such a premises may fall into this exception.

This exception usually applies when the local council gave development approval for a building design that had an insulation design where other forms or areas of insulation made up for minimal underfloor or ceiling insulation. For instance, where wall insulation made up for minimal ceiling or underfloor insulation. The landlord should provide evidence of the building specifications and of compliance with insulation requirements at the time of building.

The landlord must, however, ensure that the insulation remains in reasonable condition even if it falls into this exception.

4. Landlord Plans to Demolish or Substantially Rebuild Property within 12 months of tenancy starting

A premises does not need to meet the insulation requirements if the landlord intends to demolish the property or substantially rebuild part of it within 12 months of the start of the tenancy. For this exception to apply, the landlord cannot simply have an intention to rebuild or demolish. The landlord must have evidence of the intention to rebuild or demolish within 12 months, such as an application for building consent, redevelopment work, or resource consent.

5. When the property is sold and then immediately leased back to the previous owner-occupier for a period of 12 months or less

A premises does not need to meet the insulation requirements if the property is sold and then immediately leased back to the former owner-occupier. This exception only applies for the first 12 months of that tenancy. If the tenancy continues beyond 12 months, then the landlord must take action to meet the insulation requirements.

Read more about the exceptions

Checking your insulation

Only check insulation yourself if you can do it safely - if you can’t do it safely, then hire a qualified professional to do it for you.

EECA Energywise has helpful guides and tips on checking and installing insulation safely:

Helpful Tips

  • Professional Help - If you’re unsure whether it’s safe or what the standard of the current insulation is, you should consider hiring a qualified professional.
  • Make the Space Safe - Before you enter a ceiling or underfloor space, make sure it is safe to do so. Turn off the power at the mains, as there may be exposed live wires in the roof or ceiling - this is an electrocution risk! If there is foil insulation installed, be especially careful. You should wait for a few minutes after switching off mains power as the foil may still be conducting electricity. Proceed with extreme caution around foil insulation and avoid unnecessary direct contact with it.
  • Safety Gear - Wear safety equipment such as gloves, dust masks, overalls, glasses/goggles, sturdy enclosed footwear.
  • Assistance - Don’t check the insulation when you’re alone. Make sure an adult is nearby to help you if needed.
  • Stand on Frame in Roof - When in a roof space, ensure you stand on the frame and supports connected to it. Standing elsewhere may not support your weight and you risk damaging the ceiling or falling through it.
  • Clearances Around Lights - Ensure that insulation is clear of hot items or sources of heat such as downlights, transformers, and flues. Debris should be clear of any electrical appliances or lights - if in doubt, call a qualified electrician.
  • Avoid Hot Roof Spaces - Do not enter hot roof spaces. Wait until it has cooled down, take regular breaks, take a bottle of water, and make sure another adult is in the house to help you if required.
  • Avoid Health Risks - If you know there is a health risk in a particular area, do not enter - e.g. asbestos, exposed wires, sewage.
  • Don’t get stuck! - If a space is too small, cramped, or awkward to access, don’t risk getting stuck! Get professional help.
  • Leave the Wiring Alone! - Leave any wiring or electricity-conductive materials alone and consult the assistance of a qualified electrician.
  • Avoid Tampering with Clearances - Don’t fill in required safety clearances around electrical appliances or similar.

Read more safety insulation information

Do the walls need to be insulated?

Wall insulation is not compulsory. Installing wall insulation, where possible, may still be good practice for landlords to improve the energy efficiency and warmth of their rental property. Wall insulation may also be a selling point to attract higher-paying tenants and improve the resale value of your property.

Though wall insulation is not compulsory, you must still disclose whether there is such insulation and its nature and type as part of the compulsory insulation statement attached to a Residential Tenancy Agreement.

Further Reading from Tenancy Services

myRent strongly recommends further reading and seeking information from Tenancy services before taking any action with insulation.

Insulation Safety

Does your rental home meet the insulation standards?

Compulsory Insulation

Insulation Requirements Booklet

Warmer, drier, safer homes

Healthy Homes Standards

The information contained in this article is exclusively for promotional purposes. It does not in any way constitute legal advice and should not be relied upon as the basis for any legal action or contractual dealings. The information is not, and does not attempt to be, a comprehensive account of the relevant law in New Zealand. If you require legal advice you should seek independent legal counsel. does not accept any liability that may arise from the use of this information.

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