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MBIE’s Stern Warning to Employers

Important Legislation

4 Feb 2026 (Last updated 4 Feb 2026)

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Director and managers personally liable for employment law breaches

The Labour Inspectorate has issued a statement reminding individuals, including business directors, senior managers and legal or business advisors, they can be held personally responsible even if they are unofficially connected to a business that breaches minimum employment standards.

The reminder follows an Employment Relations Authority (ERA) determination that found three individuals were personally involved in employment law breaches at two Christchurch restaurants, and ordered them to repay more than $40,000 in arrears.

Labour Inspectorate Compliance Manager Northern, David Milne, said the penalties stemmed from ongoing non-compliance.

“The employer failed a whole raft of basic legal requirements such as providing employment agreements, maintaining accurate wage and time records, and paying minimum wage, holiday pay and leave entitlements to seven workers at two Christchurch restaurants. Instead of rectifying their practices, they denied responsibility and continued to operate as they had before. Later they sold their business,” Mr Milne said.

“From 2016, the Employment Relations Act enables persons other than the employer to be held accountable if they’re knowingly involved in breaching employment standards.”

What does this mean for employers?

It is crucial that small business owners understand their obligations under the Employment Relations Act. Non-compliance, even unintentional, can be costly and detrimental to your business.

Unlike big corporations, small businesses don’t always have in-house HR and legal departments to interpret the complex language of the Employment Relations Act. Changes to legislation and workplace compliance are becoming increasingly difficult to manage, especially for overstretched small business owners.

Yet a business, no matter how big or small, needs to have the right framework to succeed – policies and procedures are an integral component of that framework. Having solid policies and procedures not only provides direction during moments of uncertainty, but protects your business and gives you the blueprint to remain compliant.

It’s more important than ever to be compliant

From pay rates to record keeping, Peninsula is here to help. Contact us on 0800 675 700 for a confidential discussion about how we can support your business.

This article is for general information purposes only and does not constitute as business or legal advice and should not be relied upon as such. It does not take into consideration your specific business, industry or circumstances. You should seek legal or other professional advice regarding matters as they relate to you or your business. To the maximum extent permitted by law, Peninsula Group disclaim all liability for any errors or omissions contained in this information or any failure to update or correct this information. It is your responsibility to assess and verify the accuracy, completeness, and reliability of the information in this article.

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Important Legislation

Changes to Employment law: Contractors, Personal Grievances and more

The New Zealand Parliament passed amendments to the Employment Relations Act 2000 (the Act) on 17 February 2026 that will reshape the personal grievance landscape and the management of Independent Contractor agreements. Below is a summary of the key changes: 1. Specified contractor - Gateway Test The Act introduces a gateway test for specified contractors. Contractors who meet specific criteria are automatically deemed genuine contractors, preventing retrospective reclassification as an employee. A worker is classified as a specified contractor when: there is a written agreement that specifies that the worker is an Independent Contractor (or not an employee); and they are not restricted from performing work for another party the worker is: not required to work certain times or days or for a minimum period; or allowed to subcontract any work the business cannot terminate the arrangement if the worker does not accept an additional task. the worker had a reasonable opportunity to seek independent advice before entering into the arrangement. If the worker does not meet the gateway criteria, then the Authority or the Courts will look at the true nature of the relationship, irrespective of what the worker has been classified as in a contract. Misclassification of contractors can lead to hefty back-pay and legal risks. If a business hires someone as an independent contractor when the true nature of the relationship is that of employment, they may be held liable for extra costs including back payment of wages, leave entitlements and compensation if the engagement was terminated or changed without process. Compliance with the new gateway test gives small businesses clearer confidence that their worker is an Independent Contractor and will not be later re-classified as an employee. It is therefore important to ensure that your Independent Contractor agreements satisfy the gateway criteria. 2. Personal grievance remedies tightened The Act introduces changes regarding employee remedies in employment disputes, particularly when the employee is found to be at fault. Key changes Include: Removing remedies for employees whose behaviour amounts to serious misconduct. Allowing remedy reductions of up to 100% where an employee contributed to the situation causing the personal grievance. Consideration must be given as to whether the employee's behaviour hindered the employer's ability to meet their fair and reasonable obligations. The tolerance for procedural error is increased – and will focus on whether any errors in the employer’s process resulted in the employee being treated unfairly. These changes are a welcome relief to employers. However, it is important to not be complacent. The employer is still required to act reasonably and fairly in the circumstances – which means substantive and procedural requirements are still relevant and necessary. 3. Limits on personal grievance claims for high income earners The Act introduces an income threshold where employees earning above $200k per annum would generally not be able to raise an unjustified dismissal claim. However, employers and employees could still choose to opt back into these protections. These changes could offer more flexibility when hiring for senior roles, potentially reducing the risk of costly and disruptive dismissal processes if a senior hire doesn't work out as planned. Employees on existing employment agreements who meet the remuneration threshold will have up to 12-months to re-negotiate their agreements before the threshold for unjustified dismissal claims takes effect It would be important to have clear, well-documented agreements if you choose to opt in or negotiate alternative arrangements. In addition, these employees will retain their rights to raise a personal grievance for unjustified discrimination or disadvantage. As such an employer must still deal with them fairly and reasonably during their employment. 4. Removal of the 30 day rule The Act removes the requirement that the terms of a new employee’s employment agreement reflect the terms of a collective agreement for the first 30 days of employment. The related employer’s obligations in respect of information about unions and the active choice to join a union form is also removed. An employer will be required to inform an employee of the collective employment agreement and provide a copy, but the employee will no longer be subject to its terms unless they become a member of the union. Empower your business today Peninsula is here to help you navigate the potentially confusing definitions associated with employment. Our advice line is available day or night, so feel free to contact us whenever engaging new staff to ensure you are meeting your obligations.

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