Common questions about RIA changes
Overview
This page provides additional guidance on the Regulatory Impact Analysis changes introduced on 1 July 2026 and answers common questions from agencies about the new requirements.
What is expected for a Regulatory Analysis Summary (RAS)?
Overview
The Regulatory Analysis Summary (RAS) is a summary document, not a record of all analysis undertaken. RASs should be no more than 20 pages.
Agencies should still undertake analysis proportionate to the significance of the proposal. Detailed analysis can sit behind the RAS (for example in briefings or working papers) and can be proactively released alongside Cabinet materials, following decisions.
See guidance on preparing, quality assuring and publishing RASs:
The Regulatory Analysis Summary Process – Guidance Note
RASs are expected from 1 July 2026
All papers (that include regulatory policy proposals) taken to Cabinet on or after 1 July 2026 must prepare a RAS.
The 20-page limit for RASs
RASs should be 20 pages or less. Agencies should have a strong justification for a departure from the 20-page expectation.
While a RAS provides a summary of analysis to Cabinet, agencies must also undertake appropriately detailed analysis, including providing briefings for Ministerial decisions, to prepare for Cabinet policy approvals.
Agencies may wish to proactively release this information, and it will be subject to the Official Information Act 1982. For more information, see Cabinet Circular: CO (23) 4.
Cabinet Circular: CO (23) 4: Proactive Release of Cabinet Material: Updated Requirementsopen_in_new
We encourage agencies to submit an early draft of their RAS to their QA panel. The assessors may:
- ask to see some of the linked/referenced material
- consider whether the length of the RAS is proportionate to the significance of the policy problem in their feedback.
See more on preparing and quality assuring RASs in our guidance notes:
Sections 10 and 11 of the Regulatory Analysis Summary Process Guidance Note cover using the RAS template:
Regulatory Analysis Summary Process Guidance Note
Proposals without a RAS or with a 'does not meet' rating
In cases where impact analysis requirements are not met, there is no requirement for supplementary analysis after Cabinet decisions are made. However, agencies still need to prepare a Consistency Accountability Statement (CAS) and Summary of Underpinning Analysis when legislation is introduced or made.
Agencies without a RAS to support their Summary of Underpinning Analysis are more likely to identify an inconsistency with some of the principles of the Regulatory Standards Act.
New legislation is also subject to review as part of the Regulatory Standards Act’s requirements for existing legislation, unless it is excluded from the Act.
Legislation excluded from the Regulatory Standards Act
We publicly report on the number of Cabinet proposal considered without a RAS.
Section 14 of the Regulatory Analysis Summary Process Guidance Note covers proposals with inadequate impact analysis.
Regulatory Analysis Summary Process Guidance Note
When deregulatory options are required
A deregulatory option is context specific. It could include:
- options for lighter-touch regulation, or
- removing regulation entirely.
RASs must demonstrate an agency has considered a range of feasible options.
Where there is existing regulation, a deregulatory option should be included in the set of options. It should include analysis on the impact of removing it or moving to lighter touch regulation.
If a deregulatory option is not relevant, it is not required as part of the RAS. For example, where a proposal would introduce regulation for the first time, there may be no deregulatory option to assess.
In addition, where a deregulatory option is obviously not workable (e.g. the deregulation of a serious crime), a brief justification is sufficient, rather than an exhaustive analysis.
The role of the RIA Team in determining RAS requirements
The Ministry's RIA Team is still responsible for confirming the process requirements for impact analysis, including QA panel arrangements.
See Section 10 of the Regulatory Analysis Summary Process Guidance Note to find out more about confirming a RAS process.
Regulatory Analysis Summary Process Guidance Note
Updates to the cost recovery templates
We have made minor updates to the Stage 1 and Stage 2 cost recovery impact analysis templates (CRIS 1 and CRIS 2).
These are now called:
- Stage 1 Cost Recovery Impact Analysis (CRAS1) template
- Stage 2 Cost Recovery Analysis Summary (CRAS2) template.
These new cost recovery templates will undergo a complete review later in 2026.
Stage 1 Cost Recovery Analysis Summary (CRAS 1) template (232 KB, Docx)
Stage 2 Cost Recovery Analysis Summary (CRAS 2) template (238 KB, Docx)
How does the exemption process work now that agencies are responsible for this process?
Internal processes for exemption decisions
Agencies are now responsible for RAS exemption decisions from 1 July 2026.
Agencies must have an internal process for ensuring exemption decisions are made appropriately. For example, the team responsible for developing a policy proposal and recording an exemption with the Ministry for Regulation should ideally not be the same one confirming the exemption is appropriate.
Section 8 of the Regulatory Analysis Summary Process Guidance Note covers the exemptions process and grounds.
The Regulatory Analysis Summary Process – Guidance Note
Monitoring and auditing exemption decisions
The Ministry will audit exemption decisions periodically. We are developing a monitoring and reporting policy and will keep agencies updated.
Recording exemption decisions
Agencies need to record their exemption decision and reasoning in RIA Online.
What happens if I have a regulatory proposal already underway under the previous RIA requirements?
Missing or inadequate RAS
If a new proposal has a missing or inadequate RAS, you do not need to prepare:
- a supplementary analysis report (SAR), or
- a post implementation report (PIR).
For SARs already underway
If you are preparing draft legislation that will be approved by Cabinet Legislation Committee after 1 July 2026, and your legislation is subject to CAS requirements, you do not need to complete your SAR even if it is underway.
Contact us to confirm whether this applies to your proposal:
For PIRs already underway
You are not required to complete your post-implementation review if your legislation is included in a plan for review of existing legislation (required under the Regulatory Standards Act).
Contact us to confirm whether this applies to your proposal:
What are the requirements for discussion documents and interim RASs?
If a discussion document contains a full range of feasible options (i.e. it does not narrow options under consideration):
- quality assurance (QA) is no longer required
- it is not necessary to apply for a discussion document exemption.
If a discussion document narrows options or does not present a full range of feasible options:
- an interim RAS is required and must be quality assured
- proposal details must be entered in RIA Online for process confirmation.
Agencies should:
- apply their own QA processes to ensure discussion documents are of a high standard
- use the quality assurance criteria in the discussion document guidance, although this is not mandatory.
See more information in the Discussion Documents and the Regulatory Analysis Summary requirements Guidance Note:
Discussion Documents and the Regulatory Analysis Summary requirements Guidance Note
What is the relationship between the RAS and CAS systems?
A Consistency Accountability Statement (CAS) does not replace a RAS
A RAS supports Cabinet decision-making on regulatory proposals.
A CAS discloses any inconsistencies with the principles of responsible regulation which have been identified with legislation.
The two documents serve different purposes and are required at different times in the regulatory making process.
RAS requirements
A RAS must accompany policy proposals taken to Cabinet (or two or more Ministers with delegated authority from Cabinet) if they include a government regulatory proposal, unless an exemption applies.
An exemption from completing a RAS does not provide an exclusion from requirements (such as producing a CAS) under the Regulatory Standards Act 2025.
CAS requirements
A CAS must be produced for all proposed legislation (Government bills, material Government amendments, and secondary legislation) unless the legislation is excluded or exempted.
CASs must be included in, or linked to, from the explanatory note of the Bill, Government amendment or new secondary legislation.
Legislation excluded from the Regulatory Standards Act
Cabinet Circular CO (26) 2: Expectations for Good Law-makingopen_in_new
RAS exemptions and CAS exclusions are separate
A proposal that is exempt from RAS requirements may still need to meet CAS requirements under the Regulatory Standards Act 2025.
Legislation excluded from CAS requirements are either included in:
- Schedule 2 of the Regulatory Standards Act, or
- The Regulatory Standards (Excluded Legislation) Notice 2026.
More information about the CAS requirements for new legislation:
CAS requirements for new legislation
Find out about exemptions from the RIA requirements in section 9 of our Guidance Note on the Regulatory Analysis Summary Process:
The Regulatory Analysis Summary Process – Guidance Note
Where can I find more guidance and support?
We ran webinars in June 2026 that covered a range of topics including:
- changes to the RAS template
- the new exemptions process
- discussion documents
- the process for inadequate impact analysis
- publication requirements.
For central government agencies, the webinars are available on demand in RIA Online.
We also presented at a Policy Project webinar on the changes to RIA in May 2026.
Watch the presentationopen_in_new
For more information on the following topics, see our Regulatory Impact Analysis resources:
- best practice guidance
- guidance on the RAS process
- quality assurance
- discussion documents,
- publication requirements
- information on cost benefit analysis.
Also see The Cabinet Circular CO (26) 2: Expectations for Good Law-making on the DPMC website:
CO (26) 2: Expectations for Good Law-makingopen_in_new