Parliament has passed significant changes to New Zealand’s restricted trading day alcohol rules — removing the “substantial meal” requirement for on-licences, extending cellar door rights for wine producers, and enabling RSAs to welcome the general public on Anzac Day morning.

Key Points at a Glance

• The Sale and Supply of Alcohol (Sales on Anzac Day Morning, Good Friday, Easter Sunday, and Christmas Day) Amendment Bill passed its third reading on 1 April 2026 by 66 votes to 56.
• Royal Assent is expected today, 2 April 2026. The Act comes into force the day after Royal Assent — meaning changes may apply from Good Friday, 3 April 2026.
• On-licences: Section 47 is repealed. Bars, restaurants, and hotels lawfully permitted to open may serve alcohol under normal licence conditions — no meal required, no one-hour windows.
• Off-licences: The general prohibition is retained, but the cellar door exemption for on-site wine producers (currently Easter Sunday only) is extended to all four restricted days.
• RSAs: May now serve the general public from 4 am to 1 pm on Anzac Day without a special licence. A duty manager must be on-site.
• Late trading: On-licensed premises may now continue trading past midnight into a restricted day under standard licence hours.
• Existing licence conditions inconsistent with the new law automatically cease to have effect on commencement — no DLC variation process required.

Background: New Zealand’s Restricted Trading Days

The Sale and Supply of Alcohol Act 2012 (the Act) designates four periods each year as restricted trading days for alcohol: Good Friday, Easter Sunday, Christmas Day, and Anzac Day morning (until 1 pm). These designations reflect the significance of those days in New Zealand’s social and cultural life, and the restrictions on alcohol trading have historically operated as a signal of that significance.

Under the Act, a person or business may only sell or supply alcohol if they hold one of four types of licence. An on-licence allows the sale of alcohol for consumption on the premises (bars, restaurants, hotels, cafés). An off-licence allows it to be taken off the premises (bottle stores, supermarkets, delivery services). A special licence allows alcohol to be sold at certain events. A club licence allows consumption on the premises, but generally only for club members, their guests, and reciprocal club members — with RSAs being a prominent example.

On restricted trading days, all four licence types face prohibition or significant limitation. The Act’s restrictions have operated alongside — but independently from — the general Easter trading framework under the Shop Trading Hours Act 1990. That Act, which governs whether businesses may open at all on Good Friday, Easter Sunday, and Christmas Day, is not amended by the Bill. Businesses that are currently prohibited from opening on those days will remain unable to open, and the alcohol law changes will therefore have no practical effect for them.

The Current Rules: What the Law Requires Today

On-licences (bars, restaurants, hotels, cafés)

BEFORE (Current Law) Alcohol may only be served to patrons who are:

• Residing or lodging on the premises overnight (e.g. hotel guests)
• Present on the premises to dine — meaning they have ordered a “substantial meal” — within a window of one hour before eating to one hour after finishing
• Attending an event authorised by a special licence held for those premises

AFTER (After the Amendment) Alcohol may be served to any patron:

• Under normal licence conditions — no meal condition required
• No “substantial meal” requirement; no one-hour dining windows
• No special licence needed to operate on restricted days
• Premises may trade past midnight into a restricted day under standard licence hours

The “Substantial Meal” Problem

Important Context: Under current law, a patron must have ordered a “substantial meal” for alcohol to be lawfully served — yet that term is nowhere defined in the Act. Compounding the difficulty, patrons were not required to actually eat the meal; merely ordering it was sufficient. Auckland Council guidance to restaurants advised: “only serve alcohol to customers eating a substantial meal.” In practice, however, hospitality staff were left to make real-time judgment calls on a legal standard that offered no reliable guidance. The Bill removes this requirement entirely.

Off-licences (bottle stores, supermarkets, cellar doors)

Under section 48 of the Act, off-licences are completely prohibited from selling alcohol on Good Friday, Christmas Day, and before 1 pm on Anzac Day. Easter Sunday carries the same prohibition, with one exception: wineries and other producers of grape wine or fruit or vegetable wine may sell from their cellar door on Easter Sunday, provided the wine is made on-site or from produce harvested from the land on which the premises are situated. No alcohol may be delivered by an off-licence on any restricted day.

RSAs (club licences)

RSAs operating under a club licence enjoy a statutory right to open from 4 am to 1 pm on Anzac Day, notwithstanding any local alcohol policy or individual licence condition that would otherwise prevent this. However, like all club-licensed premises, they may ordinarily only sell and supply alcohol to authorised persons — members, their guests, and reciprocal club members. Serving the general public on Anzac Day has required an annual special licence application to the relevant District Licensing Committee.

What Changes Under the Amendment Bill

The Bill was introduced as a member’s bill by Labour MP Kieran McAnulty. It passed its third reading on 1 April 2026 by 66 votes to 56, with Parliament treating the vote as a conscience matter. The changes are summarised by licence type below.

On-licences: restrictions removed

The Bill repeals section 47 of the Act in its entirety. On-licensed premises that are lawfully permitted to open on a restricted day will be able to sell and supply alcohol under their ordinary licence conditions without needing a special licence, and without any meal-based conditions. The Bill also incorporates an amendment proposed by ACT MP Cameron Luxton permitting on-licensed premises to continue trading past midnight into a restricted day. Previously, a venue was required to cease service at 11:59 pm when a restricted day commenced. Under the new law, trading may continue in accordance with the premises’ usual licensed hours.

Off-licences: general prohibition retained, cellar door extended

Following submissions to the Justice Committee raising concerns about potential alcohol-related harm, the general off-licence prohibition has been retained. Bottle stores and supermarket alcohol sections will remain closed on all four restricted days. However, the Bill extends the existing Easter Sunday cellar door exemption to the other three restricted days. Wine producers — whether grape wine or fruit or vegetable wine — may now sell from their cellar door on Good Friday, Christmas Day, and Anzac Day morning (in addition to Easter Sunday), provided the wine is made on the premises or from produce harvested from land on which the premises are situated.

RSAs: open to the general public on Anzac Day morning

The Bill removes the requirement for RSAs to hold a special licence in order to serve the general public on Anzac Day morning. From commencement, RSAs will be able to welcome members of the public from 4 am to 1 pm on Anzac Day alongside their own members. A certified duty manager must be on the premises at all times during which members of the public are present.

Summary Table: Licence Type by Licence Type

Transitional Arrangements: Effect on Existing Licences

A practically important feature of the Bill is that existing licence conditions inconsistent with the new law will automatically cease to have effect on commencement. No formal variation application to a District Licensing Committee will be required. Specifically:

Automatic Lapse of Inconsistent Conditions

• On-licences: Any condition imposed before commencement that prohibits or restricts the sale or supply of alcohol on Good Friday, Easter Sunday, Christmas Day, or before 1 pm on Anzac Day will cease to have effect.
• Off-licences (cellar door): Any condition imposed before commencement that prohibits the sale or delivery of on-site grape wine or fruit/vegetable wine on Good Friday, Christmas Day, or before 1 pm on Anzac Day will cease to have effect.
• Club licences (RSAs): Any condition imposed before commencement that prohibits the sale or supply of alcohol to non-authorised persons during the hours of 4 am to 1 pm on Anzac Day will cease to have effect.

The Bill also amends the Sale and Supply of Alcohol Regulations 2013, updating standard licence forms for on-licences and off-licences to remove references to restricted day conditions that will no longer apply.

Important Note: Licence holders should note that the automatic lapse applies only to conditions that are inconsistent with the new law. Conditions on individual licences that are more restrictive than the former statutory defaults — and which were not themselves derived from sections 47 or 48 — may not automatically lapse and should be reviewed with legal advice.

Implications for Councils, DLCs, and Licensing Agencies

Key Points for Local Government

• DLCs and licence conditions: Inconsistent conditions will lapse automatically on commencement — no formal variation process is required. DLCs and inspectors should nonetheless be prepared to advise licence holders on which conditions are affected and which may require separate review.
• Local alcohol policies (LAPs): Off-licence restrictions are being retained, so LAP provisions directed at off-licence restricted day trading are largely unaffected. However, LAP provisions relating to on-licence trading hours on restricted days may now be redundant in practice, as the national default position will permit unrestricted trading. Councils may wish to review their LAPs for consistency.
• RSA special licences: RSAs will no longer need to apply annually to DLCs for special licences to serve the public at Anzac Day services. This reduces administrative burden for both RSAs and licensing agencies.
• Duty manager compliance: RSA club-licensed premises serving the general public on Anzac Day morning must have a certified duty manager on duty at all relevant times. Licensing inspectors and Police should be prepared to monitor compliance with this new requirement.
• Enforcement clarity: The automatic lapse of inconsistent conditions addresses what would otherwise have been a period of confusing inconsistency between existing licence conditions and the new national default — a welcome development for inspectors and Police.

Commencement

The Act comes into force the day after it receives the Royal Assent. Royal Assent is expected on 2 April 2026. If granted today, the new rules will apply from Good Friday, 3 April 2026 — and to all subsequent restricted trading days, including Anzac Day morning (25 April 2026) and Christmas Day.

Practical Note for Operators

Given the proximity of Good Friday, operators should not assume the new rules are in force until Royal Assent is formally confirmed. Once confirmed, staff briefings should be updated promptly. Hospitality New Zealand has noted that decades of public conditioning around the existing restrictions mean many customers may not be aware that venues can now serve without meal requirements — clear communication to patrons is advisable.

Operators should also review any licence conditions that reference the former restricted day requirements to identify whether those conditions survive commencement.

Coming Soon

A further article in this series will address the Sale and Supply of Alcohol (Improving Alcohol Regulation) Amendment Bill, which proposes a broader overhaul of the licensing provisions under the Act, including changes affecting District Licensing Committees, licensing criteria, and enforcement.

Contact

We Can Help

If you hold an on-licence, off-licence, club licence, or operate as a licensing agency and wish to understand how these changes affect your operations, please contact our Alcohol Licensing team. We can assist with licence reviews, conditions advice, DLC proceedings, and compliance queries.

Disclaimer: This article provides a general summary of recent legal developments and does not constitute legal advice. Readers should seek specific advice in relation to their own circumstances. © Copyright AWS Legal 2026