The ceiling insulation exemption for limited roof space: what changed on 25 September 2025

Two small amendments to the Healthy Homes standards took effect on 25 September 2025. The one most landlords are looking for is a partial exemption for ceiling insulation: a newer rental with little or no ceiling space, such as a skillion or low-pitched roof, can meet the insulation standard without the usual minimum ceiling R-value, provided the building was consented after a set date, met the Building Code's insulation rules when it was built (typically by insulating walls, floors and windows more heavily), and the landlord holds the compliance document that proves it. The second change confirms that the Healthy Homes standards take priority over overlapping parts of the Housing Improvement Regulations 1947. If your rental already complied, you do not need to do anything.

Why the exemption came back

Before the Healthy Homes standards fully applied, older transitional rules, the Smoke Alarm and Insulation Regulations 2016, let some properties meet alternative ceiling insulation requirements. Those were typically houses designed under the Building Code's performance-based energy efficiency rules, where a thin or missing ceiling cavity was offset by better insulation elsewhere in the building.

Those transitional rules stopped applying to insulation on 1 July 2025, the date full Healthy Homes compliance became compulsory. That left a gap: some fairly modern houses that had been treated as compliant were suddenly caught by the standard ceiling R-value, even though they met the Building Code of their day. The government's own paper on the change noted that upgrading these ceilings could be difficult, expensive or impossible. The amendment, a new regulation 19A in the Healthy Homes Standards Regulations, restores the exemption from 25 September 2025.

Who qualifies

All four conditions have to be met:

1. There is ceiling insulation installed. The exemption relaxes the level required, it does not excuse an empty ceiling.
2. When that insulation was installed, thermal insulation requirements under an Act or bylaw applied to the building (in practice, the Building Code).
3. You hold a compliance document, such as a code compliance certificate, that certifies the building complied with those requirements with the insulation in place.
4. The building first received building consent on or after 30 September 2008 in climate zone 1, 30 June 2008 in zone 2, or 31 October 2007 in zone 3.

If all four apply, the ceiling insulation does not have to meet the minimum R-value or be installed to NZS 4246:2016. Nothing else changes: the underfloor requirement, and the rest of the insulation standard, apply as normal.

What it does not cover

• Houses consented before the dates above. Older ceiling insulation is dealt with by separate, existing transitional rules for insulation installed before 1 July 2016, set out on the Tenancy Services insulation page.
• Ceilings with no insulation at all.
• Ceiling spaces a professional installer cannot safely reach. That is a different exemption, which lasts only until access becomes possible, for example at a re-roof.
• A landlord who cannot produce the compliance document. Without it, the exemption does not apply.

The paperwork is the exemption

Regulation 19A comes with an evidence rule. During a tenancy, the tenant or Tenancy Services can make a reasonable request for evidence of the compliance document. If you do not provide it within 10 working days, the exemption stops applying. The same happens if the Tenancy Tribunal asks for it and you miss the Tribunal's deadline.

So the practical step is to find the code compliance certificate now, not when someone asks. Your council's property file is the usual place to look. Keep a copy with the rest of the property's insulation records; in Landy that means the insulation section of the rental's logbook, next to the ceiling photos.

The exemption also changes what you write in new tenancy agreements. If you rely on it, the insulation part of the Healthy Homes compliance statement must say the ceiling insulation is exempt from the minimum R-value and NZS 4246:2016 requirements, and briefly describe why.

The Housing Improvement Regulations 1947 change

The Housing Improvement Regulations 1947 are an old set of minimum housing rules that still apply to houses generally. Some of them cover the same ground as the Healthy Homes standards: heating devices, ventilation and window openings, and site drainage. Since 25 September 2025, a new regulation 7A switches off the specified 1947 provisions for rental premises covered by the matching Healthy Homes standard.

In practice, a landlord follows one set of rules for heating, ventilation and drainage rather than trying to satisfy two that do not quite line up. It does not lower any Healthy Homes requirement.

What to do now

• If your rental has a skillion or low-pitched roof and was consented after the date for its zone, get the code compliance certificate and check it covers the building with its insulation.
• If you had quotes for difficult ceiling work because of the July 2025 gap, check whether regulation 19A applies before spending the money.
• Update the insulation wording in the compliance statement for any new tenancy that relies on the exemption.
• If you are unsure which zone or rule applies, the insulation tool on tenancy.govt.nz or an insulation assessor will settle it faster than guesswork.

For the full insulation requirements, including R-values by climate zone, see our insulation standard page.