# HUD — Retirement Villages Act 2003 Review: Insurance Issues Regulatory Impact Statement (2025)

Document ID: doc-0053  
Publisher: Ministry of Housing and Urban Development  
Catalogue date: 2025-10-20  
Physical PDF pages: 32  
Original capture/access label: June 2026  
Source and content reviewed: 9 October 2026

Original local PDF: [2024 - MBIE - RIS RV Act Review Insurance Issues.pdf](/pdfs/2024%20-%20MBIE%20-%20RIS%20RV%20Act%20Review%20Insurance%20Issues.pdf)

Primary publisher source: [Publisher document or listing](https://www.hud.govt.nz/assets/Uploads/Documents/Proactive-Releases/December-RVA/02-Insurance-RIS-Signed-final-RIS-REDACTED.pdf)

## What the document contributes

HUD’s thirty-two-page regulatory impact statement finalised 20 October 2025 assesses insurance excesses, capital repayment following total loss and insurance wording that no longer reflects market practice. It favours restricting no-fault excess charges for operator property, requiring resources to meet capital-repayment obligations and modernising reinstatement insurance requirements. The analysis weighs resident protection and operator viability qualitatively because reliable incidence and cost data are limited. It supports prospective policy decisions; it neither enacts the options nor guarantees a payout under a specific insurance policy.

## Substantive findings

- The cover names the Ministry of Housing and Urban Development as responsible agency and dates finalisation 20 October 2025. The local MBIE/2024 filename is misleading; it is retained while catalogue attribution and the thirty-two-page count are corrected.
- For insurance excesses, the preferred option restricts passing costs to residents where damaged property belongs to the operator and the resident is not at fault. It is narrower than a wholesale prohibition on every excess charge.
- For total-loss events, the preferred option requires resources to meet existing capital-repayment obligations, rather than requiring repayment of the current market value of the entire unit. Capital repayment and replacement housing value are different concepts.
- The statement favours reinstatement-based insurance wording that accommodates modern sum-insured or pooled arrangements, explaining the shift from open-ended replacement cover after the Canterbury earthquakes.
- The analysis states that accurate monetisation of costs and benefits was not possible because incidence data, commercially sensitive information and future operator choices were insufficiently known. Its benefit-cost judgement is narrative, not a quantified guarantee.
- Consultation evidence comes from voluntary responses to the 2023 review and targeted stakeholder engagement, including residents, operators, insurers and statutory supervisors. Response percentages are not representative polling of the whole population.
- The document contains redactions and sets out conditional implementation proposals, including historical bill and transition timing. Its expected July 2026 introduction is superseded by the publisher’s September 2026 next-Parliamentary-term update; neither this RIS nor that announcement is enacted law.

## Identity, dates and provenance

The scanned cover names Te Tūāpapa Kura Kāinga – Ministry of Housing and Urban Development and says Date finalised 20/10/2025. The responsible manager’s signature on physical page 5 is also dated 20/10/2025. The catalogue date is that finalised analysis date, not a claimed first public-release day. The Ministry for Regulation’s library lists publication on 4 February 2026. HUD hosts the matching redacted thirty-two-page file under a December-RVA proactive-release path. The original MBIE/2024 filename is preserved despite its incorrect identity cues.

The original PDF and June 2026 capture label are preserved. The October 2026 review records source verification and catalogue enrichment; it does not replace publication or capture provenance. This companion brief is an editorial summary, not a substitute publisher document.

## Where to check the original

Physical pages 1–5: identity, preferred options, costs, benefits, limitations and quality assurance. Several pages are image-only and were visually inspected rather than treated as blank. Pages 6–14: background, problems and consultation. Pages 16–29: options analysis. Pages 30–32: transition, dissemination, oversight and monitoring proposals.

## Evidence limits and use

The statement expressly says accurate monetisation was not possible and uses narrative cost-benefit assessment. Incidence data are limited, relevant information may be commercially sensitive, and future operator behaviour is uncertain. The internal quality-assurance rating Meets supports the adequacy of this policy analysis; it does not certify every village’s insurance adequacy. Protection of capital sums following total loss is different from guaranteeing today’s market value or immediate availability of replacement accommodation. Selected legal advice and commercial details are redacted. The source’s July 2026 bill expectation is historical: the official September 2026 update says introduction in the next Parliamentary term. This brief does not infer enactment, commencement or an individual insurance remedy from either source.

## Publisher references

- [Primary publisher document or listing](https://www.hud.govt.nz/assets/Uploads/Documents/Proactive-Releases/December-RVA/02-Insurance-RIS-Signed-final-RIS-REDACTED.pdf)
- [Ministry for Regulation listing, publication 4 February 2026](https://www.regulation.govt.nz/publications-and-resources/regulatory-analysis-summaries/regulatory-impact-statement-retirement-villages-act-2003-review-insurance-issues/)
- [Current official review status, updated 18 September 2026](https://www.hud.govt.nz/our-work/retirement-villages-act-2003)
