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TLANZ Submission: Employment Leave Bill

Apr 20, 2026

The TLANZ Employment Law Committee has published a submission on the Bill set to replace the Holidays Act 2003.

The Employment Law Committee is broadly supportive of the Bill’s policy direction, viewing it as a significant and positive step toward addressing the complexity, uncertainty and systemic compliance issues that have long plagued the current framework. However, the Committee cautions that certain aspects of the Bill may create compliance challenges for employers with complex or non-standard workforce arrangements and sees scope for targeted refinement.

Without attempting a clause-by-clause review, the submission focuses on a number of discrete areas where clarification, refinement or additional guidance would materially improve the Bill’s workability to keep the regime clear, flexible and usable across New Zealand’s diverse industries.

Read the full submission here: TLANZ Supplementary Submissions on the Employment Leave Bill

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