The Fast-track Approvals Amendment Act 2025 passed its third reading in late 2025. It is the first significant tweak to the regime since it commenced in February 2025, and it makes five changes worth understanding.
1. Tightened panel timeframes
Statutory timeframes for panel decisions have been compressed. The default 30 working days for a panel decision (after acceptance as complete) is now firm with narrower grounds for extensions.
What it means: panels can no longer absorb slow client clarification responses. Applicants who fall behind on RFIs risk their decision date slipping not because the panel paused but because the panel will not accept slow input. The internal-team-readiness question on our viability quiz is now more important than it was a year ago.
2. Government Policy Statement mechanism
The Minister for Infrastructure can now issue GPSs that bind both the Minister at referral and the panel at substantive. Covered in our [GPS post](/blog/government-policy-statements-fast-track) — most material change in the Amendment.
3. Grocery retail competition limb added to s.22
A ninth benefit limb has been added: increasing grocery retail competition. This was inserted specifically to address the supermarket duopoly. New entrants now have a statutory hook they did not have when the Act passed.
What it means in practice:
- Distribution centres for new grocery players can be lodged with a clear benefit case
- Format innovations (warehouse, discount, online fulfilment) get a pathway
- The limb is narrow — generic retail does not qualify. The test is competition, not jobs
We expect to see the first grocery-limb approval within 12 months.
4. Clarified panel composition rules
Panel composition rules have been tightened to ensure Treaty/tikanga expertise is present where Māori interests are engaged. This was always the practice, but it is now legislated.
What it means: applicants whose projects clearly engage Māori interests should expect panels with a Treaty/tikanga member. The cultural impact assessment workstream needs to be ready for substantive engagement with that panel member.
5. Procedural clarifications
Several technical procedural clarifications around:
- Comment-period rules for affected local authorities and statutory parties
- Application of the EEZ Act within Fast-track
- Reserves Act interactions
- Submission-rights limits
These are not strategic shifts but they tighten the procedural surface area of the regime.
What did not change
Worth being clear on what the Amendment Act did not do:
- It did not add general public submission rights — the regime remains a closed engagement process
- It did not broaden appeal rights — appeals to the High Court on points of law only
- It did not change the s.22 benefit-limb framework substantively (other than the grocery addition)
- It did not revisit eligibility under s.17
The political bargain of the original Act — speed in exchange for narrowed submission rights — remains intact.
What it means for applicants in flight
If you are mid-engagement, two action items.
- Re-read the GPS landscape against your referral framing. Aligned? Worth surfacing. Misaligned? Worth understanding before lodgement.
- Pressure-test your team's response capacity. The tighter timeframes mean clarification responses must come back inside 7–10 working days, not 3 weeks. Set the expectation now.
For new entrants, the Amendment Act makes Fast-track slightly more predictable and slightly more political. Both are workable, both need to be planned for.