Quick answer
On a granny flat built under the 2026 exemption, the paperwork follows the licence, not the invoice. Your LBP designer signs a Certificate of Work for the restricted design. Your LBP builder signs a Record of Work for the restricted building work — primary structure and weathertightness — and gives it to you and the council that issued your PIM. Your registered plumber and drainlayer each sign one under section 27A of the Plumbers, Gasfitters, and Drainlayers Act 2006. Your electrician issues a certificate of compliance and an electrical safety certificate; a gasfitter does the same if there is gas. Your kitchen company almost certainly signs nothing, because installing cabinetry and fitting sanitary fixtures is not restricted building work. The records that close your file belong to the trades who connect the kitchen, not the one who built it.
Key points
- Restricted building work is narrow — primary structure and weathertightness — and kitchen joinery sits outside it, so your kitchen company files no Record of Work.
- All restricted building work on a granny flat must be carried out or supervised by licensed professionals; the homeowner exemptions do not apply.
- An LBP's Record of Work goes to you and the council; a plumber's under section 27A goes to you alone, and forwarding it is your job.
- Section 42B(6) defines completion as the moment you have received every record, so the plumber's and electrician's paperwork gates the notification.
- Your kitchen installer still owes a section 14E duty: work not covered by a consent must comply with the Building Code, whether or not anyone signs a form.
The kitchen company signs none of this.
The question arrives in the same shape every time. Someone is putting a two-bedroom flat at the back of a section in Te Atatū Peninsula, the PIM is issued, the slab is down, and they ring the kitchen company asking for "your LBP number and the record of work for the kitchen". There isn't one. There was never going to be one. And the week before the notification is due is a rough time to learn the document you were chasing does not exist, while the two that do are sitting unread in a plumber's ute.
What follows is the Building Act side of a granny flat: which trades must be licensed, what each signs, and which paper the council wants at the end. It is not planning advice and it is not a substitute for your own LBP. Sloping site, specific engineering, anything with gas — confirm the detail with your designer and your council before you order a cabinet.
Restricted building work is narrower than people think
Restricted building work is not a synonym for important work, nor for work a licensed person does. It is a defined slice. It applies to houses and to purely residential small-to-medium apartment buildings under 10 metres, and within those it covers three things: the primary structure, the external moisture management systems, and fire safety system design in apartments. That is the whole of it.
Primary structure means the elements resisting vertical and horizontal loads — piles and their braces, bearers, joists, slabs, studs, lintels, rafters, trusses. External moisture management means what keeps water out and controls moisture in the fabric — building wrap, drained cavities, cladding and its fixings, windows, doors, skylights, flashings. Read those lists twice and notice what is missing. No cabinetry. No benchtops. No sinks.
MBIE lists four ways work falls outside restricted building work: it is not to a house or small-to-medium apartment building; it needs no consent under Schedule 1; it does not affect the primary structure or weathertightness; or it does not fit an LBP licence class. The department's own example of the third is "fitting new sanitary fixtures where there were not any previously (such as in new kitchen or ensuite)". That is your kitchen sink, described by the regulator, in the not-restricted column.
Under this exemption, you cannot do it yourself
This is the condition people skim. Under the exemption, all restricted building work must be carried out or supervised by licensed building professionals — and the guidance adds five words in brackets that do a great deal of work: homeowner exemptions do not apply. Ordinarily an owner-builder can do restricted work on their own home. Not on one of these. MBIE puts it directly: homeowners cannot design or build granny flats themselves unless they hold the qualifications. The one carve-out is electrical and narrow: owners intending to live in the flat may use the section 79 domestic exemption under the Electricity Act 1992, and a licensed inspector must still check the work.
What each licence actually signs
Six sets of paperwork can land on a granny flat, drawn from four pieces of law. The model that helps: each document is tied to a licence, each licence to a specific Act. Who signs is decided by what they are licensed to do — not by who you contracted or who was on site last. The LBP classes are Design, Carpentry, Roofing, Brick and Blocklaying, External Plastering, Foundations, and Site. No cabinetry class. No benchtop class. No kitchen class.
| Who | Licensed under | What they sign | Who they must give it to |
|---|---|---|---|
| LBP designer | Building Act, design licence | Certificate of Work identifying the restricted design work and stating it complies with the Building Code | You, with the final design plans. You pass it to the council. |
| LBP builder | Building Act, section 88(1A) | Record of Work stating what restricted building work they carried out or supervised | You and the council that issued the PIM |
| Registered plumber | PGD Act 2006, section 27A | Record of Work for the prescribed sanitary plumbing | You, the owner. Forwarding it is your job. |
| Registered drainlayer | PGD Act 2006, section 27A | Record of Work for the prescribed drainlaying | You, the owner |
| Registered electrician | Electricity (Safety) Regulations 2010 | Certificate of compliance, plus an electrical safety certificate once connected to supply | You, and whoever contracted the work if readily available |
| Gasfitter (only if there is gas) | Gas (Safety and Measurement) Regulations 2010 | Certificate of compliance, plus a gas safety certificate | You, and whoever contracted the work if readily available |
| Your kitchen manufacturer | Nothing — not restricted building work | No Record of Work, no certificate | Nobody |
Two details cause most of the confusion. The first is that the LBP's Record of Work is the only one with a statutory route to the council: section 88(1A) requires it to be issued to the owner and to the territorial authority that issued the PIM. The plumber's record under section 27A goes to the owner and stops there — if you assume your drainlayer filed it, nobody filed it. The second is that these documents are personal, not corporate. A Certificate of Work must come from an individual, not on behalf of a company, and each designer and builder provides one for their own work.
Your kitchen company signs nothing. It still owes you something.
Here is where honest beats impressive. A kitchen supplier offering to "provide the LBP paperwork for the kitchen" is either talking about someone else's paperwork or has not read the scheme. But the absence of a form is not the absence of a duty. Section 14E of the Building Act catches builders, and a builder there includes anyone carrying out building work, in trade or not. A builder whose work is not covered by a consent must ensure it complies with the Building Code. No exception for cabinetmakers. Your kitchen installer holds a real Building Code duty and files nothing about it.
So you hold a kitchen company to account contractually, not through the regulator. No Record of Work will ever appear on the property file with our name on it. What should exist instead is a contract naming the scope, a warranty you have read, and quality records from the install — because councils do not inspect exempt work at all, so nobody is coming to check. What a kitchen warranty covers and what it quietly doesn't is worth more here than any Building Act form.
Complete is a definition, not a feeling
The kitchen going in feels like the end of a build. Legally it is nowhere near it. Section 42B(6) says the work is complete when the owner has received, from the relevant designers, builders, plumbers, drainlayers, electricians and gasfitters, the records of work required under sections 88 and 27A, and all certificates of compliance and safety certificates for electrical and gas work. Received. Not done, not paid for, not promised.
From there you have 20 working days to send the pack to the council that issued the PIM, along with the final design plans and the Certificate of Work required by section 45AA. Miss it and it is an infringement offence, with a fee, and a fine if prosecuted. The council assesses none of it for Building Code compliance — they add it to the property file, where it surfaces on future LIMs and matters to your insurer, your bank and your buyer.
The electrical rule sharpens the timing again. Under regulation 65 of the Electricity (Safety) Regulations 2010 the work is not complete until the certificate of compliance is issued, with a record of inspection too for high-risk work. The hob is not finished when it is live. It is finished when the certificate exists.
Nobody rings the kitchen mob for a record of work until the week it's due. Then they're surprised there isn't one, and they've still got a sparky who reckons he sent his certificate weeks ago.
Complete is a definition, not a feeling.
What goes wrong
The kitchen company gets treated as a link in the compliance chain. It isn't one. The kitchen is the visible thing on site in the last week, so it absorbs the attention while the paperwork that matters gets generated by a plumber over two hours on a Tuesday.
The section 27A record gets assumed into existence — the most common failure on these jobs by a distance. An LBP's Record of Work has a legal path to the council. A plumber's does not. It comes to you, it sits in your inbox, and because a document arrived everyone feels covered. Nobody has sent it anywhere. Under section 42B(4) that duty is the owner's, and it does not shift because a main contractor is on the job.
The as-built drift goes unrecorded. The waste comes up 300mm off, so the sink moves, so the cabinet run changes, so the dishwasher lands on the other side — and a new circuit lands with it, meaning another electrician visit and another certificate. None of that is a fault. It becomes one when the final design plans still show the original layout, because those plans must reflect what was built and must carry a Certificate of Work from a design LBP. This is where the gap between plan measure and site measure becomes a filing issue, and why getting the trade order right beats chasing paper at the end.
The rental angle gets found late. The exemption does not require family to live there, so plenty go straight onto the market — at which point the Healthy Homes Standards apply and the kitchen touchpoint is extraction, where a recirculating rangehood is not always sufficient on its own. Deciding whether the rangehood ducts out or recirculates is close to free at design stage and painful once the ceiling is lined. If it will be tenanted, read what landlords have to get right in the kitchen before the plans are final.
What to ask before you sign
- Which named individual holds the design licence, and are they contracted to certify the final design plans at completion — not just draw the originals?
- Which LBPs are doing or supervising the restricted building work, and does each know they owe a Record of Work to you and the council?
- Is the section 27A Record of Work written into your plumber's and drainlayer's scope, and who chases it?
- Who forms and flashes the rangehood duct penetration, and does it sit inside somebody's Record of Work?
- Has anyone confirmed in writing that the kitchen supplier owes no Building Act paperwork?
- Who collates the completion pack, and by what date, given the PIM lapses two years from issue?
Frequently asked questions
Does my kitchen installer need to be an LBP on a granny flat?
Generally no. Restricted building work covers the primary structure, external moisture management and fire safety design in apartments, and installing cabinetry sits outside all three — MBIE's own example of work that is not restricted is fitting new sanitary fixtures where there were none previously, such as in a new kitchen. If the work alters the primary structure or cuts through the cladding, that is a different conversation, so ask your LBP first.
Who files the Record of Work for the kitchen?
Nobody files one for the cabinetry, because there is nothing to file. The registered plumber files a Record of Work under section 27A for the prescribed sanitary plumbing, the drainlayer does the same for the drainlaying, and the LBP builder files one under section 88(1A) for the restricted building work. The kitchen generates no Record of Work of its own.
My plumber gave me his Record of Work — does he send it to the council, or do I?
You do. Section 27A of the Plumbers, Gasfitters, and Drainlayers Act 2006 requires the plumber or drainlayer to provide the record to the owner of the dwelling, and that is where their obligation ends. Only the LBP's Record of Work under section 88(1A) must go to the council as well. Under section 42B(4) sending the completion pack is the owner's duty, so assume you are collating everything.
Can I install the kitchen in my own granny flat myself?
The joinery itself is not restricted building work, so the licensing condition does not bite there — but section 14E still makes you responsible for Building Code compliance, and a builder for that purpose includes anyone carrying out building work, in trade or not. The connections are another matter: sanitary plumbing, drainlaying, electrical and gas work are restricted to registered and licensed people, and MBIE is explicit that the usual homeowner exemptions do not apply here.
Is the granny flat complete when the kitchen is finished?
No, and that gap is where people get caught. Section 42B(6) defines the work as complete when the owner has received the records of work, certificates of compliance and safety certificates from the relevant designers, builders, plumbers, drainlayers, electricians and gasfitters. A physically finished kitchen with an uncertified hob is not a complete building, and your 20 working days to notify the council has not started.
What a kitchen manufacturer is actually for
We are not in your compliance chain and will not pretend to be. Your designer draws and certifies, your LBP builds and records, your plumber and drainlayer sign under section 27A, your electrician certifies, and you send the pack. What we can do is keep the kitchen from being the reason your notification is late: a layout that respects the drain line, a duct path agreed before the ceiling closes, an install slotted into the programme so the plumber and sparky fit off while still on site.
We build in our own workshop in East Tamaki, turn out ten-plus kitchens a week, and install over five to seven days. Supply and install sit under one contract and one invoice — one person to chase rather than a supplier in one suburb and an installer in another. No showroom, so the pricing is trade rather than retail. Send the plans, even the preliminary set that went in with your Form 2AA, and a trade-priced number comes back inside 24 hours, plus GST.