ECE Licensing Changes: Your Action Plan for 20 April 2026
- 6 days ago
- 4 min read
Keywords: ECE, licensing criteria, early childhood education, compliance, MOE, policy
The new ECE licensing criteria take effect on 20 April 2026. In this article we help you decide where to put your energy over the next few weeks.
We talk through changes in detail, in the video recording of our "Licensing changes made simple webinar".
What's changing
The new criteria consolidate and merge existing requirements — if you're meeting compliance now, you're largely in good shape.
The criteria numbers are all changing.
The MOE website has been redesigned with a new section: How we will assess compliance — the content is useful as a self-review tool.
A small number of changes require new forms or process changes before 20 April.
Stop collecting immunisation records
This one took affect on 8 January 2026 — NZ Health now manages this nationally.
Actions
Stop collecting immunisation certificates from families.
For current enrolments, archive immunisation records (keep them as evidence for ERO — don't destroy).
Check your SMS provider has removed immunisation fields from the enrolment process.
Your current medication registers and long-term medication forms will likely need to be updated before 20 April.
Privacy note: You cannot keep collecting immunisation records even if parents offer them. Under the Privacy Act, you can only hold information you're legally required to have. The requirement has been removed, so collecting this information puts you in breach of your privacy obligations.
Medication administration — new categories, new forms
This is the most involved change. The current three-category system is moving to two categories.
Your current enrolment form references old medication categories and immunisation fields. You don't need to redo forms for currently enrolled families — a notice to parents covering the changes is sufficient. The Ministry has published an updated version in its recent bulletin.
What it was | What it becomes |
Cat 1 — centre-supplied first aid preparations | Removed from compliance — no parent sign-off required (best practice: still inform parents what you use). |
Cat 2 — short-term parent-supplied medications (antibiotics, eye drops) | New Category (i) — Parents no longer need to sign medication in every morning. They can sign for a full course upfront. You still document every administration, and the parent still signs daily to acknowledge medication was given. |
Cat 3 — long-term medications (inhalers, EpiPens) | New Category (ii) — The 3-monthly re-sign requirement is removed. Instead, agree with the parent on an appropriate check-in frequency. |
Actions
Your current medication registers and long-term medication forms will likely need to be updated before 20 April.
Issue a notice to parents communicating the changes.
All new enrolments from 20 April will need an updated enrolment form.
Emergency drills frequency change
Minimimum drill frequency is changing from 3-monthly to 4-monthly. Before you shift your schedule:
Actions
Check your FENZ obligations — if you're on a 3-monthly or 6-monthly notifiable drill schedule, a move to 4-monthly may not align.
Use this as a prompt to complete your annual Emergency Management Plan review.
If your 3-monthly cycle is working well, continuing it keeps you fully compliant.
Operational review
Self-review and internal evaluation becomes "review" under GMA104. The substance is similar. Internal evaluation isn't gone — it moves under the curriculum criteria, where it connects to reviewing your programme's effectiveness.
Quick decisions
These can take less than an hour to work through. Most require a simple team decision followed by a minor documentation update.
Thermometers
Any fixed wall thermometer must be out of reach of children and be positioned no higher than 1500mm above the floor. Some centres prefer to use a portable thermometer.
First aid kits
The Ministry's specific mandatory list moves from compliance to recommendation. Stock your kit based on your children's needs, with a good replenishment system. Update your process documentation accordingly.
Fridge temperatures (lunchbox centres)
Minimum fridge temperatures shifts from 4°C to 5°C fpr non MPI centres. MPI centres will no longer be part of the ERO review. Update your forms and procedures where they reference 4 degrees.
Annual plans and budgets (full licence)
No longer checked by Ministry or ERO for full licence holders. Probationary licence holders still need them. If your annual plan works for you, keep it — it's still good practice. Ministry just won't be auditing it.
Whānau information sharing
Required display items reduce to three: your current licence, any licence conditions, and complaint contact information. Everything else can move online or to another format — you need to tell parents where to find it.
Philosophy statements
No longer part of the licensing criteria, but still valuable for your centre's identity and curriculum. If yours is working well, keep it. Review it when it's next due, and decide then whether to evolve it.
MOE notifications
The list of notifiable events has been clarified and extended. Read the updated criteria. A child leaving the centre without an adult — even briefly — is now explicitly notifiable.
HR criteria
Some items removed from the licensing criteria (including professional growth cycles) — but these still apply under Teaching Council requirements. No real change in practice.
Daily hazard checklist
Add earthquake proofing, including checking secured furniture and top-of-cupboard items, to your daily check.
The deadline for changes
Legally, you need to be meeting the new criteria from 20 April. This includes changes to your policies, procedures and other areas affected.
If you haven't started you should start now.
Using ECEDocs to get ready
All ECEDocs policies will be updated to reflect the new criteria by 20 April. Subscribers also receive termly advisory emails expaining what's changed and what action is needed — one place, plain language, clear next steps.
The platform links each policy directly to its licensing criteria, and a document management feature is in development so you can store your templates and forms alongside your policies.
If you'd like a walkthrough, book a demo. Or take the compliance quiz to see where your focus needs to be.
