At the same time, the Employment Court's decision in Soapi v Pick Hawke's Bay has redrawn the boundaries of lawful wage deductions, and Sustainable Winegrowing New Zealand (SWNZ) is raising the bar on its People pillar.

What the RSE Reforms Actually Change

The RSE changes were announced on 28 July 2026. The reforms — which are the result of a sporadic, multi-year policy review — cover accreditation, cost recovery, pastoral care, worker mobility, and compliance, and implementation is staged from early 2027 [1].

The most significant structural shift is graduated accreditation. New employers will initially receive a one-year accreditation term. Employers who build a strong compliance record become eligible for longer terms of three or six years [1, 2]. This means your documentation history is not just a paperwork exercise — it directly determines how often you face re-accreditation scrutiny.

On cost recovery, the reforms introduce a clear list of costs that employers can recover from workers, together with a standard cost-recovery agreement that must be signed before workers travel to New Zealand [1, 2]. This is a material change: workers will know exactly what they are agreeing to before they board the plane, and employers will need to match what is in that agreement against what actually appears in payroll.

Pastoral care requirements are also being strengthened. Internet access at worker accommodation will become a prescribed requirement, helping RSE workers stay connected with family and communities [1, 2]. For Marlborough and Hawke's Bay operations that house workers in on-farm accommodation, this is a facility upgrade worth planning and budgeting for now.

Worker mobility provisions are being eased, making it simpler for RSE workers to move between accredited employers in certain circumstances — for example, following unforeseen weather events or business disruptions that limit available work [2]. Vineyards operating under joint ATR arrangements should review their agreements in light of this flexibility.

The Soapi v Pick Hawke's Bay Ruling and What It Means for Deductions

The backdrop to many of the cost-recovery reforms is a landmark Employment Court decision: Soapi v Pick Hawke's Bay [2025] NZEmpC 208 [2]. Three Solomon Islands RSE workers challenged a range of wage deductions — covering accommodation, food, fuel, clothing, bedding, protective gear, airfare recovery, visa costs and wage advances — that left workers with only $100 per week in hand [2]. The Court found those deductions breached the Wages Protection Act 1983 and the Minimum Wage Act 1983 [2].

The ruling established a critical point on accommodation deductions: they must be capped at 5% of wages, unless a "cash value" reflecting market rates has been lawfully fixed and specified in the individual employment agreement [2]. The employer in this case had not specified a fixed cash value in the individual employment agreement; instead, the amount to be deducted for weekly rent was listed solely in the deductions consent form approved by INZ under the ATR process [2]. The Court declared this was not compliant. The cash value must appear in the employment agreement, not just in a separate consent form.

A Court of Appeal decision on Pick Hawke's Bay was still pending as of August 2026 [2]. Check the current status before finalising your deduction agreements.

The practical implication for Marlborough and Central Otago vineyards is straightforward: if you deduct accommodation costs, your employment agreements must state a dollar cash value that reflects market rates. If you cannot demonstrate that, you are exposed.

SWNZ's People Pillar: Evidence, Not Just Policy

The June/July 2026 issue of New Zealand Winegrower highlighted that SWNZ is strengthening its People pillar, with ethical employment practices described as a "hot topic" in key markets [3]. The driver is partly the requirements of Nordic monopoly buyers, who now expect not only written employment policies but demonstrable evidence that those policies are being implemented on the ground.

This is a meaningful shift. Having an employment policy document filed somewhere is no longer enough. SWNZ auditors — and, by extension, the export markets your wine reaches — will expect to see that the policy is alive: training records, incident logs, worker feedback mechanisms, and documentation that processes are followed vintage after vintage.

For RSE employers, this intersects directly with the reforms. A vineyard in Hawke's Bay that can show clean deduction agreements, properly documented accommodation cash values, signed cost-recovery agreements, and consistent timesheet records is not just RSE-compliant — it is building exactly the kind of People pillar evidence that SWNZ now requires.

What to Document Before 2027: A Practical Checklist

The convergence of RSE reform, the Soapi ruling, and SWNZ's People pillar requirements points to the same set of records.

Timesheets and work records

Every RSE worker's hours must be recorded accurately, by block and by task where possible. Per-block labour costing — tracking which crew worked which parcel, for how many hours, at what rate — creates an audit trail that satisfies both Labour Inspectorate scrutiny and your own cost-of-goods calculation. Marlborough operations running multiple blocks across different sub-regions will find granular labour records invaluable when margins tighten.

Deduction agreements

The standard cost-recovery agreement, once finalised by INZ, must be signed before workers travel. Keep a signed copy on file for every worker, matched to their employment agreement. Cross-check that every deduction listed in the agreement actually appears in the employment agreement itself — particularly accommodation cash values.

Accommodation cash values in employment agreements

Following Soapi, accommodation deductions are capped at 5% of wages unless a market-based cash value is specified in the employment agreement. Document how that value was calculated, and review it against current market rates before each season.

Other cost-recovery records

The reforms introduce a defined list of recoverable costs. Any deductions outside that list carry legal risk. Keep records that tie each deduction category to the approved list, and retain the signed cost-recovery agreement as evidence of informed consent.

Employment policies with implementation evidence

For SWNZ People pillar purposes, pair every written policy with an evidence layer: induction records showing each worker received and understood the policy, records of any complaints or concerns raised, and how they were resolved.

Pastoral care records

Document internet access arrangements at worker accommodation. When the prescribed requirement takes effect, you will want records showing provision was in place from the outset.

Pulling It Together for the 2027 Vintage

The reforms are staged from early 2027, landing squarely on the vintage season. For Central Otago operations — where harvest runs later than Marlborough and the RSE workforce is a critical component of picking capacity — the window to prepare is tighter than it looks.

The smartest move is to treat the documentation exercise as one integrated project rather than three separate ones. The records that satisfy INZ's new cost-recovery transparency rules are the same records that demonstrate SWNZ People pillar implementation. The timesheet discipline that underpins per-block labour costing also underpins minimum wage compliance. Build the system once, and it serves every audit.

Vineyard management software that records field work orders, block-level labour allocation, and harvest data by lot can anchor your documentation framework. Cepaos, for example, covers blocks and parcels, field work orders, harvest intake with lot traceability, and costing and finance — a connected record-keeping platform designed for vineyards and wineries.

The RSE scheme, as the Minister noted, has been a standout success for nearly 20 years [2]. The 2026 reforms are designed to make it simpler, clearer, and more protective of workers — and the operations best placed to benefit are those whose records are already in order [1].

Ready to build a documentation system that holds up under RSE, SWNZ, and Labour Inspectorate scrutiny? Learn how Cepaos supports New Zealand vineyard record-keeping.

Sources

Changes announced to the Recognised Seasonal Employer scheme — Immigration New Zealand, accessed 8 November 2026. https://www.immigration.govt.nz/about-us/news-centre/changes-announced-to-the-recognised-seasonal-employer-scheme/
NZ's seasonal worker program: simplified processes and stronger worker protections - Devpolicy Blog from the Development Policy Centre — Devpolicy Blog from the Development Policy Centre, published 20 August 2026. https://devpolicy.org/nzs-seasonal-worker-program-simplified-processes-and-stronger-worker-protections-20260821/
New Zealane Winegrower Magazine - New Zealand Wine — nzwine.com, accessed 9 November 2026. https://www.nzwine.com/en/media/nzwm/