New Zealand's regulator opens a consultation on balcony solar it is not allowed to permit, and on export limits for small generators

New Zealand's Electricity Authority Te Mana Hiko opened a combined issues and Code amendment consultation on 8 September 2026, titled "Exploring plug-in generation and Code improvements for export limits and connection processes". The paper itself is dated 7 September 2026. Submissions close at 5pm on Tuesday 6 October 2026, on the forms in Appendices C and D of the paper, to connection.feedback@ea.govt.nz.

It is two documents stapled together. One half asks open questions about plug-in generation, the plug-into-a-socket panels known elsewhere as balcony solar, which are currently illegal to use in New Zealand. The other half proposes five specific amendments to the Electricity Industry Participation Code 2010 covering export limits and small-scale connection processes. The second half is where the enforceable content is.

The five Code proposals

Since May 2026, clause 6.3A of the Code has given small-scale distributed generation a default export limit of 10 kW under the streamlined Part 1A application process, which a distributor may only set lower if it has run a network study showing a lower setting is necessary to maintain voltage or network safety. That matters for reading this consultation correctly: the 10 kW default is not being introduced here. It already exists, and the proposals are repairs to it found in the first months of operation.

Proposal 1 would extend the 10 kW default to the Part 1 application process rather than Part 1A alone. Applicants whose systems do not meet a distributor's connection and operation standards are pushed onto the slower, costlier Part 1 route, and the Authority says the policy intention was never for them to lose the export entitlement as a result.

Proposal 2 would stop distributors restricting their approved inverter lists to smart communicating inverters only, or requiring dynamic or flexible export limits, through their connection and operation standards. The Authority frames this as protecting a consumer's choice to retain a static export limit at this stage.

Proposal 3 would let distributors build in a buffer of 10 per cent extra distributed generation penetration when performing a network study to assess hosting capacity at an installation control point or group of points, and so decide whether a limit below 10 kW applies. The stated purpose is to reduce how often distributors must reassess hosting capacity.

Proposal 4 would clarify that distributors must offer applicants both the Part 1A and Part 1 processes. Proposal 5 would clarify that distributors cannot request extensions to the 10 business day Part 1A notification timeframe, while stopping the clock for the period a distributor is waiting on further information from an applicant.

The half the Authority cannot decide

Plug-in generation is prohibited in New Zealand by a WorkSafe New Zealand prohibition notice. The Electricity (Safety) Regulations 2010 belong to MBIE and the Minister for Energy; WorkSafe is the agency that enforces them. The Authority states in the paper that under the status quo it does not consider any Code amendment creating an explicit pathway for plug-in generation to be necessary, that the notice is currently under review, and that it does not assume any particular outcome of that review. Its consultation page puts it more bluntly: whether plug-in generation becomes legal is "a decision for other regulators". The Authority says it is working with MBIE, WorkSafe, EECA and Standards New Zealand.

What it is doing instead is pre-drafting the participation questions. It asks whether plug-in generation would affect network power quality and what would mitigate the risk; whether a register of devices is needed, and whether that should be a notification or registration rather than an application requiring distributor approval; what information a registration should carry; and whether retailers rather than distributors should be the primary customer interface. It records that Germany operates a simplified registration that does not require distributor approval, that a number of jurisdictions cap plug-in systems at 800 W maximum export, and that Germany allows the DC nameplate rating of the panels to exceed 800 W on the basis that some generation is self-consumed rather than exported. It also names the problem portability creates for any register: a device that moves address makes the record stale, and compliance with an update requirement may be low in practice.

Tim Sparks, the Authority's General Manager Networks and System Change, said plug-in generation "has the potential to expand access to self-generation" for New Zealanders traditionally excluded from technologies such as rooftop solar, naming renters and apartment owners.

Why it matters

Almost every rooftop solar regime in the world is built around a household that owns its roof and can pay an installer, which quietly excludes renters and apartment dwellers from generating anything at all. A plug-in panel is the cheapest known route around that exclusion, and the barrier is not economics. It is an electrical safety instrument written before anyone sold a generator in a box, administered by an agency whose mandate does not include market participation. Watching a market regulator draft the participation rules for a device another regulator still bans is an unusually clear view of the permission layer deciding who gets to be a producer.

The sharper item, though, is Proposal 2. Some New Zealand distributors have been requiring communicating inverters, which is the precondition for dynamic export limits and therefore for remote control of a household's exports. The Authority's proposed answer is that a consumer may keep a static limit and a non-communicating inverter unless a network study says otherwise. That is a regulator drawing a line between participation and controllability, and deciding a distributor acting alone cannot make the first conditional on the second. Proposals 1 and 2 still let distributors offer dynamic and flexible limits. They stop them being the only door.

Proposal 3 cuts the other way, and is the one to watch. A 10 per cent hosting-capacity buffer reduces distributor reassessment work, and it also gives distributors a defensible basis for justifying limits below 10 kW earlier than they otherwise could. The Authority describes this package as an interim approach and says a separate issues and consultation paper on how to enable dynamic and flexible export limits is in preparation. The consumer's static 10 kW option is explicitly framed as holding "at this stage".

What is still unknown

Who is conducting the review of the WorkSafe prohibition notice, on what timetable, and whether any of the Authority's plug-in work is contingent on its outcome. The paper says the notice is under review and does not say by whom, or when it reports. [UNVERIFIED: the prohibition notice itself was not read, so its legal basis and scope are taken from the Authority's characterisation of it.]

Whether an 800 W export cap would be adopted in New Zealand. The paper records that other jurisdictions use one and says a similar limit may or may not be applied here.

How an export limit would be enforced on a device that plugs into a socket behind the meter. The paper raises voltage rise, hosting capacity constraints for other network users, invalidated protection assumptions and conflicts with existing export agreements as risks, without resolving the enforcement question.

Whether registration, if introduced, would be mandatory and at what capacity threshold. The paper asks the question rather than proposing an answer.

[NEEDS DATA: the installed count of small-scale distributed generation connections in New Zealand, and typical export limits by distributor, which is what would size how much the 10 kW default actually changes.]

Sources

Electricity Authority Te Mana Hiko, consultation page, "Exploring plug-in generation and Code improvements for export limits and connection processes": https://www.ea.govt.nz/projects/all/network-connections/consultation/exploring-plug-in-generation-and-code-improvements-for-export-limits-and-connection-processes/

Electricity Authority, consultation paper, dated 7 September 2026, 770 KB PDF: https://www.ea.govt.nz/documents/10844/Exploring_plug-in_generation_-_Consultation_paper.pdf

Electricity Authority media release, 8 September 2026, 10:38am, carrying the Tim Sparks quote and the statement that the WorkSafe position is under review by Government: https://www.scoop.co.nz/stories/BU2609/S00090/consultation-launched-on-future-plug-in-generation-and-distributed-generation-improvements.htm

Appendix C submission form: https://www.ea.govt.nz/documents/10845/Appendix_C_-_Submission_form_NGv6IbP.docx

Appendix D submission form: https://www.ea.govt.nz/documents/10846/Appendix_D_-_Submission_form_fxoBx3N.docx