The Law Association of New Zealand’s Property Law Committee has made a submission to the Social Services and Community Committee on the Residential Tenancies (Registration of Boarding House Landlords) Amendment Bill.
The bill aims to protect tenants in boarding houses, some of the most vulnerable people in New Zealand’s rental market, by requiring landlords to register before they can operate. The committee supports the intent. Its concern is that the bill, as drafted, falls short of what is needed to achieve it.
The Committee submits that the core problem is structural with the bill meaning landlords are required to be registered not the properties themselves. Without a requirement to register each boarding house, operators may be able to avoid scrutiny by restructuring ownership or tenancy arrangements. Auckland Council inspections in 2025 found that most illegal boarding houses, when investigated, simply changed their paperwork rather than their practices. The committee is recommending that the registration regime cover both landlords and properties.
The submission also raises several drafting concerns. The disqualification provisions that prevent certain landlords from registering do not currently extend to trusts, incorporated societies or limited partnerships, meaning some operators could structure their way around them. The Law Association’s submission finds the phrase “person concerned in the management of the company” is undefined and inconsistent with how similar legislation treats it, creating uncertainty about who is caught by the disqualification rules.
On compliance thresholds, the committee questions whether the $5,000 trigger for disqualification is appropriately calibrated, noting it may capture minor or historical breaches rather than the serious, repeat offending the bill is designed to address.
The committee also raises practical questions about the public register: whether it will be searchable by property address, not just landlord name, and whether annual re-registration is necessary given the administrative burden it would place on both landlords and the Registrar.
The submission concludes that protecting boarding house tenants requires visibility over the properties they live in, not just the people who own them. The submission maintains that registration of both is the standard the bill should set.
The full submission is available here – 20260611-TLANZ-Property-Law-Submission-on-Residential-Tenancies-Registration-of-Boarding-House-Landlords-Amendment-Bill
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