The RMA 1991 has its own definition of "working day." Most people assume it matches the Holidays Act, or the ADLS/REINZ property agreement definition, or just general office intuition about what days count. It does not match any of them exactly — and one difference in particular catches planners, applicants, and consent authorities regularly.
The RMA working day definition starts excluding days on 20 December — not Christmas Day. That is five days before Christmas. An application with a 20-working-day clock running in late November has a significantly later effective deadline than it appears.
The RMA Definition of "Working Day"
Section 2 of the RMA 1991 defines "working day" as any day of the week other than:
- Saturday or Sunday
- Waitangi Day, Good Friday, Easter Monday, ANZAC Day, the Sovereign's Birthday, Matariki, and Labour Day
- Any day in the period commencing on 20 December in any year and ending with 10 January in the following year
Three things worth noting:
Christmas Day and Boxing Day are not listed separately. They do not need to be — they fall within the 20 December to 10 January block. New Year's Day is the same.
Regional anniversary days are not listed. This is the difference that surprises most practitioners. The Holidays Act treats regional anniversary days as non-working days for employment purposes. The ADLS/REINZ ASP excludes the regional anniversary day for the property's province. The RMA s2 definition does neither — regional anniversary days are RMA working days.
A consent deadline falling on Auckland Anniversary Day (26 January 2026) is not automatically extended under the RMA. The day counts.
The Key Statutory Timeframes
Non-notified resource consents: 20 working days (s115)
The consent authority must grant or refuse a non-notified application within 20 working days of receiving a complete application under s115(1) RMA. The clock starts the first full working day after the consent authority receives an application that meets the s88 requirements — correct information, correct fees, complete form. An incomplete application does not start the clock.
Notification decision: 20 working days (s95)
The consent authority must decide whether to notify an application within 20 working days of receiving a complete application. The notification decision (non-notified, limited notification, or full notification) then determines the subsequent processing path.
Limited notification: 20 working days from close of submissions
Once the submission period closes for a limited-notification consent, the consent authority has 20 working days to make its decision.
Further information requests: the clock stops (s92/s88C)
A further information request under s92 suspends the processing clock. The suspension is given effect by s88C, which excludes the period from the date of the request until the applicant provides the information (or advises they will not). The remaining processing days then resume from where the clock stopped.
The Quirks That Cause Problems
Quirk 1: The clock stops on 19 December, not 24 December
The RMA exclusion period begins on 20 December. That means 19 December is the last RMA working day before the summer shutdown. The exclusion period ends with 10 January — meaning 10 January is the last excluded day. The first RMA working day of the new year is the next weekday after 10 January.
In 2025/26, 10 January 2026 is a Saturday. The first RMA working day of 2026 is Monday 12 January.
An application received on 28 November 2025 with a 20-working-day clock does not get a late December deadline. It gets a January deadline. Here is why:
- Day 1: Monday 1 December (first full working day after receipt on 28 November, a Friday)
- Days 1–15: 1–19 December (15 working days before the shutdown)
- 20 December to 10 January: excluded
- Days 16–20: 12–16 January 2026
The effective deadline: Friday 16 January 2026 — nearly three weeks after the calendar "feels" like 20 working days should have elapsed.
Practical takeaway: For any consent application lodged in November or early December, the applicant's expected timeline and the legal deadline are not the same. The exclusion period absorbs what looks like progress.
Quirk 2: An application lodged in mid-December is barely behind an application lodged in late November
Because the exclusion period starts 20 December regardless of when the application arrived, a complete application lodged on 15 December and one lodged on 1 December can have very similar effective deadlines in January.
This creates a perception problem: applicants who lodge early in December do not get a proportionately earlier decision. The Christmas exclusion flattens the queue. Anyone expecting a December decision for a mid-November application needs to count carefully — 20 working days from late November runs to mid-December, which is achievable. But the margin is thin.
Quirk 3: ANZAC Day 2026 is observed on Monday 27 April — not Saturday 25 April
In 2026, ANZAC Day (25 April) falls on a Saturday and is mondayised to Monday 27 April. For any RMA period that spans late April, 27 April is the excluded day — not 25 April.
This is the same issue that affects property settlement and payroll, but it is easy to get wrong in a planning context where practitioners may be accustomed to simply excluding 25 April as a standing rule. In 2026, excluding 25 April and counting 27 April as a normal working day will give an incorrect deadline.
Practical takeaway: In 2026, diarise 27 April (not 25 April) as the ANZAC Day exclusion.
Quirk 4: A s92 request on day 15 does not give the authority a fresh 20-day period
When a further information request is made under s92, the processing clock suspends via s88C. What it does not do is reset. If the authority makes a s92 request on day 15 of a 20-working-day period, receives the information three weeks later, and the clock resumes — the authority has 5 remaining working days, not 20.
This is frequently misunderstood by applicants who assume a further information request resets the window. It does not. It simply pauses and then resumes from where it stopped.
Practical takeaway: Track the running day count alongside any s92 suspension. When the information is returned, calculate how many working days remain and when the new deadline falls.
Quirk 5: An incomplete application does not start the clock at all
The 20-working-day period runs from receipt of a complete application under s88. If the consent authority determines the application is incomplete — missing required information, incorrect fee, insufficient documentation — the clock has not started.
As an administrative practice, many authorities issue a formal acknowledgement of receipt when the application is accepted as complete. This is useful for tracking purposes, but the statutory clock runs from when the application is first lodged in a form that meets the s88 requirements — the acknowledgement itself is not the legal trigger. An application submitted on 1 March but not meeting s88 requirements until 15 March has a clock that started on 16 March.
Practical takeaway: If you have not received an acknowledgement within a few working days of submission, follow up. While the acknowledgement is not itself the statutory trigger, it is the clearest practical indicator of when the authority considers the application complete.
Quirk 6: Regional anniversary days count — which means the authority has more effective time than you might expect
Because regional anniversary days are not excluded under the RMA s2 definition, a consent authority in Auckland has 20 full working days in which to process an application — including Auckland Anniversary Day (26 January 2026). The applicant who expects a one-day extension around Auckland's anniversary will not get it.
The same applies to Wellington Anniversary Day (19 January), Otago Anniversary Day (23 March), and every other regional anniversary. These are all working days for RMA processing purposes.
This is the opposite of what applies under employment law and under the ADLS/REINZ ASP. It is worth stating clearly rather than assuming consistency across legal frameworks.
2026 RMA Calendar: Traps by Period
| Period | Effect on RMA working days |
|---|---|
| 20 Dec 2025 – 10 Jan 2026 | Exclusion period. First RMA working day of 2026 is Mon 12 Jan |
| 19 Jan 2026 (Wellington Anniversary) | Working day under RMA — not excluded |
| 26 Jan 2026 (Auckland Anniversary) | Working day under RMA — not excluded |
| 6 Feb 2026 (Waitangi Day) | Excluded |
| 3–6 Apr 2026 (Good Friday, Easter Monday) | Both excluded. Four-day gap in effective working days |
| 27 Apr 2026 (ANZAC Day observed) | Excluded. Note: 25 April is not the excluded day in 2026 |
| 1 Jun 2026 (King's Birthday) | Excluded |
| 10 Jul 2026 (Matariki) | Excluded |
| 26 Oct 2026 (Labour Day) | Excluded |
| 20 Dec 2026 | Exclusion period begins again |
How Planners and Applicants Use the Calculator
Applicants: On lodging a complete application, run the calculator to determine the s115 deadline. If you receive a s92 further information request, note the date the clock stopped and recalculate the remaining days and new deadline when the information is provided.
Consent authorities and processing officers: Use the calculator to set the statutory deadline on receipt, and to recalculate the adjusted deadline after any s92 suspension. Run calculations with RMA-specific settings: the Christmas exclusion applies, but regional anniversary days do not (unless your council's own processes treat them differently — in which case that is an internal policy choice that does not affect the statutory deadline).
Frequently Asked Questions
Q: What is the standard timeframe for a non-notified resource consent?
A: Twenty working days from receipt of a complete application under s115(1) RMA 1991. The clock can be suspended by a further information request under s92. The Christmas/New Year period (20 December to 10 January) does not count as working days under the RMA definition.
Q: Does the Christmas exclusion apply from Christmas Day or from 20 December?
A: From 20 December. Not Christmas Eve, not Christmas Day — the exclusion begins on 20 December. A 20-working-day clock running in late November may hit the exclusion period before it completes, pushing the deadline into January.
Q: Are regional anniversary days excluded from RMA working day counts?
A: Based on the RMA s2 working day definition, no — regional anniversary days are not listed as exclusions and are therefore working days for RMA purposes. This differs from the position under employment law and the ADLS/REINZ ASP.
Q: What happens if the consent authority doesn't decide within 20 working days?
A: The failure to process within time does not automatically grant or refuse the consent. Applicants should seek advice on the available remedies under the RMA, which may include applying to the Environment Court.
Q: When does a s92 further information suspension end?
A: When the applicant provides the requested information, notifies the authority they will not be providing it, or the authority's stated deadline for response passes. The remaining processing days (those left when the clock stopped) then resume.
Q: What counts as "receipt of a complete application" for s115 purposes?
A: Receipt of an application that meets the requirements of s88 RMA — correct content, correct fees, adequate information. Many authorities issue a formal acknowledgement as an administrative practice, but the statutory clock runs from when the application is first lodged in a form meeting s88 requirements.
Q: In 2026, is the ANZAC Day exclusion on 25 April or 27 April?
A: 27 April (Monday). ANZAC Day falls on Saturday 25 April 2026 and is mondayised to Monday 27 April. The legal public holiday under the RMA definition is the observed date. Any RMA period that spans late April must exclude 27 April, not 25 April.
Sources & Further Reading
- Resource Management Act 1991 — s2 (definitions), s88 (applications), s92 (further information), s95 (notification), s115 (time limits)
- Ministry for the Environment — resource consent processing
- New Zealand Legislation — RMA current version
This guide is for general information only and does not constitute legal or planning advice. RMA timeframes are subject to amendment — always verify against the current Act and seek advice from a qualified RMA practitioner for application-specific deadlines.