Christopher Luxon wants voters to believe a second National-led term would start fast. At a Browns Bay rally he unveiled a 26-point 100-day plan, saying “turning around Labour’s mess was never going to be a three-year job and National needs more time to finish it.”
The pitch is speed and discipline. The business test is different. Most of the items that matter to employers, exporters and property owners cannot be finished by ministers. They depend on regulators, councils and agencies that move at their own pace, and that is where 100-day plans tend to come unstuck.
Mostly a greatest hits album
Little in the plan is new. The paid parental leave extension, the push to break up Foodstuffs and the tougher consent rules were all announced separately between July and September. The document released the week before the election is a sequencing exercise, not a fresh programme.
That is not a criticism in itself. Consolidating commitments into a dated list is more accountable than leaving them scattered across press releases. But it means the plan should be judged on what it forces to happen, not on how it reads.
Three kinds of promise
Sort the 26 items and they fall into three buckets.
The first is hard, dated and measurable: paid parental leave reaching 27 weeks from July 2027, a rates cap of 2 to 4 percent, and legislation requiring the Commerce Commission to report on separating Foodstuffs within six months. These have numbers attached and can be checked.
The second is housekeeping. The Budget Policy Statement and Budget Responsibility Rules happen regardless of who governs. Listing them pads the count.
The third is multi-year work rebadged as a 100-day action: a ten-year clinical trials target, the continuing Public Service Transformation programme, Home Energy Fund development. For these, “100 days” can only ever mean “started”.
Employers should note the parental leave item belongs firmly in bucket one. It is costed into workforce planning whether or not anyone else delivers on time.
Speed has a bill that arrives later
The last 100-day plan showed how pace is bought. In 2024, Treasury recommended suspending formal quality assurance of Regulatory Impact Statements for 100-day proposals, swapping it for post-implementation reviews a year after enactment. Scrutiny was deferred, not skipped.
This is a habit of every government in a hurry, not a National quirk. Treasury records show the incoming 2017 government also loosened impact analysis for its 100-day plan, and that from March 2020 47 Covid-era proposals received suspensions. Even the headline items kept generating Cabinet paperwork well after the window closed, with a Regulatory Standards Bill report-back dated December 2024, more than a year after the government took office.
For business, that matters. Rules written under urgency are the ones most likely to be revisited, and regulatory churn is a cost in its own right.
Last time’s scorecard was softer than advertised
The 2023-24 plan carried 49 commitments. A subsequent RNZ report card found a large share were repeals or promises merely to begin work, and that some items, including work on renewable energy and a National Infrastructure Agency, were ticked off because ministers had received advice from officials.
Industry noticed. In January 2024 Campbell McGregor, then at Harrison Grierson, called the consenting changes “a band-aid approach” and lamented “the vagaries of the political cycle once again affecting infrastructure priorities.” In health, the NZ Health Reform Collective warned in March 2024 that “the need for speed” carried policy and political risks, after sector groups had no chance to give input on major changes.
Watch the agencies, not the announcements
The structural problem is that the people holding the pen are not the people doing the work. As Webfit News puts it, the Commerce Commission, councils, Police, schools, health providers, Immigration NZ and businesses all have roles, and “announcing a policy is centrally controlled, but delivering its benefits often requires coordination across organisations with different responsibilities and constraints.”
Take the two items with the biggest commercial consequences. A rates cap only bites if councils actually rein in spending rather than shifting costs into fees, levies and deferred maintenance. A Commerce Commission report on Foodstuffs is a report, not a breakup, and any structural separation would take years and invite litigation.
The useful test, as Webfit argues, is a report card tracking “which institutions are responsible for the next stage”. If National is re-elected, business should demand exactly that in early 2027: every unfinished item, a named lead agency and a date. Without it, the plan will once again be marked complete on the strength of advice papers, and the bottlenecks it promised to clear will still be sitting there.
Sources
- RNZ: National sets out first actions if re-elected in 100 day plan (2026-10-25)
- ODT: National sets out 100 day plan if re-elected (2026-10-24)
- Webfit News: National’s 100-Day Plan Has 26 Promises. But Who Holds the Stopwatch? (2026-10-25)
- RNZ: 100-day plan report card – 15 items’ completion up for debate
- DPMC: Proactive Release CAB-23-SUB-0468 – 100-Day Plan (2024-03)
- Treasury: OIA Response 20240126 – 100 Day Action Plan regulatory commitments (2024-03)
- Treasury: OIA Response 20230568 – Suspension of RIAs between 2017 and 2023 (2024-03)
- Ministry for Regulation: T2024/171 Regulatory Standards Bill – 100 Day Cabinet report-back (2024-12-09)
- ACENZ: The government’s 100-day plan – a mixed bag (2024-01-24)
- NZ Health Reform Collective: Health Service and System and the 100 day-plan in New Zealand (2024-03-13)
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