The Two Council Touchpoints for a Granny Flat: PIM and Completion

By the MTN Kitchens & Joinery workshop team · East Tamaki, Auckland · 2026-07-13 · 12 min read

23+ years in trade · 2,000+ kitchens supplied & installed across Auckland · Laminex NZ fabricator

A granny flat under the 2026 exemption needs no building consent, but two council steps stay mandatory: a PIM on Form 2AA before you start, and a completion notification within 20 working days.

Quick answer

The granny flat exemption that took effect on 15 January 2026 removes the building consent, not the council. Two interactions stay mandatory. Before any work starts you apply for a Project Information Memorandum on Form 2AA, giving a description of the building work and preliminary design plans; the council must issue the PIM within 10 working days of a complete application, and you cannot start until it does. Then, within 20 working days of finishing, you send that same council your final design plans, Records of Work, Certificates of Work, and the certificates of compliance for electrical and gas work. Failing to send that pack is an infringement offence. The kitchen sits at both ends: its layout and drainage go in with the preliminary plans, and the plumber's and electrician's paperwork closes the file.

Key points

  • The exemption removes the building consent and the inspections, but not the council — you deal with them once before you start and once when you finish.
  • You apply for the PIM on Form 2AA with a description of the work and preliminary design plans, and the council must issue it within 10 working days.
  • A PIM is not an approval — councils do not approve or refuse a granny flat, they give site information and say whether the design looks likely, unlikely or unclear.
  • At completion you have 20 working days to send the final plans, Records of Work, Certificates of Work and the electrical and gas certificates — and that clock starts only once you hold every record.
  • The kitchen is the last trade on site, so the plumber's record of work and the electrician's certificate of compliance are often what the notification is waiting on.

No consent still means two trips to the council.

Picture a wide back section in Papakura, the sort with a driveway running down the side to a lawn nobody uses. The owner wants a two-bedroom flat at the rear for his mother, and he has read that since January he needs no consent for it. He is right. What he is not expecting is the two envelopes — one before the diggers arrive, one after the last tap is fitted — and that the second is the one people get wrong.

This covers the building consent side: the PIM you apply for before you start, the pack you send when you finish, and where the kitchen sits in each. It is not planning advice. The resource consent side runs on its own track under the national environmental standard for detached minor residential units, and district plan rules still apply — confirm both with your council before you commit to a footprint.

The exemption removed the consent, not the compliance

The change that commenced on 15 January 2026 lets you build one new, single-storey, standalone, self-contained dwelling of 70 square metres or less without a building consent. The Building Code still applies in full. Restricted building work must still be carried out or supervised by a Licensed Building Practitioner, and sanitary plumbing and drainlaying by registered people. You lose the consent application, the plan check and the inspections. You gain responsibility — if any condition is not met, the work was never exempt and a consent was required all along.

The conditions reward reading properly. The 70 square metres is internal floor area measured between the finished internal faces of the external walls, and an attached or internal garage counts inside it. Single storey, no part-storey, no mezzanine. Maximum four metres above the floor. At least two metres from any other residential building and any legal boundary, never straddling one. Lightweight timber or steel frame, roof cladding no more than 20 kilograms per square metre. And wholly new — converting the existing sleepout does not qualify.

Touchpoint one: the PIM, before anything is ordered

You apply on Form 2AA. The application must contain a description of the proposed building work and preliminary design plans. The council checks it is complete, then must issue the PIM within 10 working days. If it is incomplete they can ask for what is missing, and the clock pauses until you provide it — the practical argument for sending proper drawings rather than a sketch and a hope. No building work may begin before the PIM is issued for the final site.

Be clear about what a PIM is not. It is not an approval — councils do not approve or refuse granny flats under this exemption. What it gives you is site information: heritage status, existing stormwater and wastewater systems, who the network utility operator is and how to connect, plus bylaws, covenants and contaminated ground. Alongside it the council attaches a document saying whether your proposal is likely, unlikely or unclear against four criteria — standalone, wholly new, 70 square metres or less, single storey — and a statement on natural hazards. If a development contribution is payable, a notice comes with it, due within 20 working days after completion. The PIM lapses if the work is not completed within two years.

What the kitchen contributes at PIM

Your preliminary design plans include the kitchen, and the kitchen is where the plumbing decisions get made. Where the sink goes determines where the waste runs, and this exemption is unusually prescriptive about drainage. Systems must connect to network utility operator systems where available, and be built to E1/AS1, E1/AS2 or E1/VM1 for surface water, G12/AS1 or G12/AS3 for water supply, and G13/AS1 with G13/AS2, or G13/AS3, for foul water. Sort the layout against the drain line now, not after the slab is poured.

On top of those acceptable solutions sit hard numbers that catch people out. No more than 30 fixture units. No pumped systems within the dwelling. Main drain no less than DN100 at 1:60. Branch drains no less than DN65 at 1:40. No uncontrolled water heating. Fixture units measure the load a fixture puts on the system, and 30 is a whole-dwelling budget — the kitchen sink and dishwasher count alongside the bathroom and laundry, not separately. Have your drainlayer do that sum at PIM stage, especially if you are squeezing in a second bathroom. Finding out after the drainage is in the ground is not a variation, it is a rebuild.

Two more kitchen items belong in the early conversation. The dwelling needs an independent point of supply for electricity, so the oven, hob and dishwasher circuits sit on that rather than spurring off the main house. And G3 Food preparation and G4 Ventilation are live Building Code clauses whether or not a consent exists, which makes how you extract cooking moisture a compliance question, not a preference. Then size does the rest: at 70 square metres including any garage, a scullery is a fantasy and the kitchen is a galley or an L. Only a downgrade if designed badly — compact layouts that still feel generous come from bench runs and door swings.

The two touchpoints, side by side
Touchpoint one: PIMTouchpoint two: completion
WhenBefore any building work startsWithin 20 working days of completing the build
You supplyDescription of the work, preliminary design plansFinal design plans, Records of Work, Certificates of Work, electrical and gas certificates
Council mustIssue the PIM within 10 working days of a complete applicationReceive and store the records on the property file
Council does notApprove or refuse the building workAssess the documents for Building Code compliance
Kitchen's partLayout, sink position, fixture units, drainage runsPlumber's record of work, electrician's certificate of compliance
If you skip itThe work is not exempt and a consent was requiredInfringement offence, and a fine if prosecuted

Touchpoint two: notifying completion

When the build is finished you have 20 working days to send documentation to the council that issued the PIM — that council, not any council. The pack is the final design plans for building, sanitary plumbing and drainlaying work; the Records of Work from the licensed people who did the restricted building work; the Certificates of Work for the restricted design work; and the certificates of compliance and safety certificates for electrical and gas work.

The subtlety that costs people money is in the words final design plans. They must accurately reflect what was actually built — identical to the PIM plans, or updated to record variations. They must be prepared by an LBP holding a design licence and accompanied by Certificates of Work for the restricted design work. So if the sink shifted 600mm because the drain was not where the drawing said, the as-built plans have to say so and a design LBP has to certify them. That is where what the site measures versus what the plan says stops being a joinery problem and becomes a paperwork problem.

The timing has a nuance worth knowing. MBIE's guidance is explicit that if any records are still to come from a licensed professional, the building is not considered complete — the 20 working days runs from when you hold them all. That sounds like breathing room. It is not, because the two-year PIM lapse runs from the issue date regardless. A plumber who takes six weeks to send a record of work does not extend your two years.

What does the council do with the pack? In compliance terms, nothing. They record that it arrived and store it on the property file. They cannot review built plans to determine Building Code compliance, and have no duty to assess what you send. It surfaces on future Land Information Memorandums, which is why it matters for insurance, lending and resale. They do keep their enforcement powers — a Notice to Fix remains available if the build is non-compliant or dangerous.

The consent's gone, so everyone relaxes. Then you're twenty working days from a deadline chasing an electrician for a certificate he's convinced he already sent you.

The kitchen's certificates arrive last and gate the file.

What goes wrong

The kitchen is last, and the certificates are last with it. A kitchen goes in over five to seven days at the tail of the build, and the plumber and electrician do their fit-off in the final couple of days. Those visits generate the record of work for the sink and dishwasher, and the certificate of compliance for the hob, oven and dishwasher circuits. The last trades on site hold the documents that gate your notification. If you have not thought about who is booked when and in what order, you find out the hard way.

Nobody owns the pack — the most common failure by a distance. The homeowner assumes the builder is sending everything; the builder sends his Record of Work and considers himself finished; the electrician sends the certificate of compliance to whoever contracted him, who may be the builder, not the owner. Everyone has done their bit and nothing has been collated. The obligation sits with the homeowner, and it does not move because a main contractor is involved.

The as-built plans quietly stop matching. The waste came up 300mm off, so the sink moved, so the cabinet run changed. None of that is a problem in itself — it is a problem when the final design plans still show the original layout and no design LBP has been engaged to update and certify them.

The rental angle gets missed. The exemption does not require a family member to live there — renting it out is fine. But the moment it is tenanted the Healthy Homes Standards apply, and the kitchen touchpoint is extraction. A recirculating rangehood is not always sufficient on its own: cheap to get right at PIM stage, expensive to retrofit into a finished ceiling. If you plan to rent it, read up on what landlords have to get right in the kitchen before the plans are final.

What to ask before you sign

  • Who applies for the PIM, and who pays for the preliminary design plans that go with it?
  • Which LBP holds the design licence, and are they contracted to update and certify the final design plans at completion — not just draw the originals?
  • Has the drainlayer done the fixture unit sum for the whole dwelling, kitchen sink and dishwasher included, against the 30 unit cap?
  • Does the kitchen layout run by gravity to a branch drain at DN65 and 1:40, with no pump anywhere inside?
  • Is the rangehood ducted, and where does it terminate — decided now, not on install day?
  • Who collates the completion pack, and by what date, given the PIM lapses two years from issue?

Frequently asked questions

Do I really need a PIM if my granny flat does not need a building consent?

Yes. The exemption removes the building consent, not the PIM. Under the Building Act no building work may begin on a non-consented small standalone dwelling before a PIM has been issued for its final site. You apply on Form 2AA, and the council must issue it within 10 working days.

What happens if I forget to notify the council when the granny flat is finished?

Failing to provide the required documentation within 20 working days of completion is an infringement offence under the Building Act, carrying an infringement fee and a fine if it goes to prosecution. The council can also issue a Notice to Fix. Separately, missing records surface on a future LIM — exactly when your bank, insurer or buyer starts asking questions.

Does the council check my granny flat kitchen complies with the Building Code?

No, and this is the part people misread. Councils receive and store the completion records but have no duty to assess them, and cannot review built plans to determine Building Code compliance. Compliance is the homeowner's legal responsibility, shared with the licensed people who did the work — though councils retain the power to issue a Notice to Fix.

Can I put an island with a sink in a 70 square metre granny flat?

An island is possible within the footprint, but a sink in it is genuinely difficult. The exemption prohibits pumped systems within the dwelling, so the waste must run by gravity to a branch drain of at least DN65 at a grade of 1:40. That usually pins the sink close to the drain line, which in practice means a wall run.

Who sends the Records of Work to the council, me or my builder?

Both, in different ways. LBPs provide their Record of Work to the homeowner and to the council that issued the PIM, and plumbers and drainlayers must provide a record of work to the homeowner for prescribed sanitary plumbing or drainlaying. But the obligation to send the complete pack within 20 working days sits with the owner — assume you are collating it yourself.

Where a kitchen manufacturer fits into this

Most of the above is not a kitchen company's job, and we will not pretend otherwise. Your designer draws the plans, your LBP certifies them, your drainlayer does the fixture unit sum, and you send the pack. What a kitchen manufacturer can do is stop the kitchen holding up your notification: a layout that works with the drain line rather than against it, a ducted extraction path agreed before the ceiling closes, and an install slotted into the programme so the plumber and electrician issue their paperwork while everyone is still on site.

We build in our own workshop in East Tamaki, turn out ten-plus kitchens a week, and install a kitchen 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 you pay trade rather than retail. Send us the plans, even the preliminary set going in with your Form 2AA, and a trade-priced number comes back inside 24 hours, plus GST.

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