Minimum stockholding obligation
The Fuel Industry Act 2020 was amended in 2023 to require fuel industry participants, who meet certain criteria, to keep a minimum amount of fuel on hand within New Zealand’s Exclusive Economic Zone.
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This is the minimum stockholding obligation. It ensures New Zealand has enough petrol, diesel and jet fuel available if there is a major disruption to our fuel supply.
The Fuel Industry Act 2020 Part 4 describes the minimum stockholding obligation.
Fuel Industry Act 2020 Act Part 4 Promotion of resilience of engine fuel supplies in New Zealand(external link) — New Zealand Legislation
The Fuel Industry Regulations 2021 set out the detailed requirements that must be met.
Fuel Industry Regulations 2021 Part 5 Promotion of resilience of engine fuel supplies in New Zealand(external link) — New Zealand Legislation
Who needs to comply
The minimum stockholding obligation applies to fuel industry participants (‘obliged persons’ under the Act), who:
- import petrol, diesel, or jet fuel, and
- own or operate a bulk storage facility for that fuel or have the right to draw that fuel from one.
Minimum stockholding obligation
Minimum stockholding obligation for a compliance (reporting) period is based on average daily demand or consumption for the 12-months ending 4 months before the compliance (reporting) period begins. For example, the obligation for June is calculated from average daily demand or consumption for the 12 months ending 31 January of that year.
The minimum amount of fuel you must hold depends on the type of fuel you supply. This is set at:
- 28 days’ cover of petrol
- 24 days’ cover of jet fuel
- 21 days’ cover of diesel.
On 1 July 2028, if you are a fuel importer with more than 10% market share, your minimum diesel obligation will increase to 28 days’ cover. There is further information in the upcoming changes section below.
There are also specific requirements for holding jet fuel at or near Auckland Airport.
See more information on the minimum stockholding obligation:
Fuel Industry Regulations 2021 32 Imposition of obligation(external link) — New Zealand Legislation
Fuel Industry (Fuel Resilience) Amendment Regulations 2025(external link) — New Zealand Legislation
Entitlement agreements
Under the Act and the Regulations, you can enter an agreement with another person or company to count their fuel stocks towards meeting your own stockholding obligation. After the agreement, the person or company who holds the right to count the fuel becomes the obliged person for compliance. The fuel stock cannot be counted twice.
If you enter into an entitlement agreement, you must:
- keep records of the agreement and any material changes to the agreement
- provide a copy of the agreement to the Chief Executive of MBIE (and any changes) if asked
- keep these records for 7 years after the agreement has expired or is cancelled.
Transitional provision
You may apply for a transitional arrangement if you are unable to comply with the minimum stockholding requirement within the 2-year period after 1 January 2025.
This option is only available if:
- circumstances beyond your reasonable control have prevented you from meeting your obligation, and
- you’ve made your best efforts to comply.
In these cases, you may submit terms and conditions (such as a compliance plan) for MBIE to consider.
If accepted:
- we will publish a summary of the terms and conditions, and our reasons for accepting them
- the terms and conditions are treated as if they are an enforceable undertaking under section 66 of the Act.
See more about enforceable undertakings and compliance plans:
Fuel Industry Act 2020 Section 67 Matters included in undertakings(external link) — New Zealand Legislation
Fuel Industry Regulations 2021 50 Compliance plans included in undertakings(external link) — New Zealand Legislation
Ministerial exemptions
The Minister for Energy may grant an exemption from the minimum stockholding requirement if exceptional circumstances beyond your control prevent, or will prevent, you from meeting your obligation.
Examples of exceptional circumstances may include:
- a natural disaster that has affected fuel storage facilities
- a crisis that has affected international shipping routes.
The criteria for exemption are set out in section 59 of the Act.
Fuel Industry Act 2020 Section 59 Exemptions from stockholding obligation(external link) — New Zealand Legislation
If approved, exemptions will be published on the below page, in the New Zealand Gazette, and presented by the Minister in the House of Representatives.
More about Ministerial exemptions:
Minimum stockholding obligations Ministerial exemptions
Not meeting your obligations
We have a range of tools and interventions to encourage compliance and respond if people don’t meet their obligations.
Our compliance approach to minimum stock holding obligations
Stopping importing
If you plan to stop importing fuel, permanently or indefinitely, you must give at least 2 months’ notice and provide certain information as set out in the Regulations.
This information may include:
- identifying the relevant type of fuel
- confirming whether you will also cease to own or operate a minimum stockholding obligation storage facility, or cease to have the right to draw fuel from one
- explaining your reasons for ceasing to be an importer of that type of fuel, including any reasons that relate to monitoring fuel resilience or for planning and implementing the stockholding obligation
- providing the timeframe that you will stop importing that fuel
- providing the details of any interested party likely to become a fuel importer, or take over instead of you.
Contact us in advance so that we can help ensure you provide the information required.
Fuel Industry Regulations 2021 48 Notice of intention to cease importing obligation fuel(external link) — New Zealand Legislation
Upcoming changes
The Fuel Industry Regulations have been amended to require that at least 10 days of jet fuel at 80% of average demand is to be held at or near Auckland Airport. These amendments will come into force on 1 November 2026.
The minimum stock of 80% will be calculated based on the average demand for the relevant month of the previous year. It must also exclude tank heels, described as "stock at the bottom of tanks that is not normally disturbed".
Fuel Industry (Fuel Resilience) Amendment Regulations 2025(external link) — New Zealand Legislation
Further amendments to the Regulations require obliged persons with more than 10% market share to hold an additional 7 days of diesel from 1 July 2028. This is in addition to the 21 days of diesel cover that is currently required.
Fuel Industry (Diesel Resilience) Amendment Regulations 2025(external link) — New Zealand Legislation
A review of the regulations will be undertaken in 2026 to determine whether all importers will be required to hold an additional 7 days stock of diesel.
Read the Minister's announcement of the increased fuel reserves.
Increased diesel reserves to improve resilience(external link) — Beehive.govt.nz
The minimum stockholding obligation regime will be reviewed in 2030.
Contact us
If you need more information on stockholding obligations including information on compliance, ministerial exemptions or to notify us of your intention to cease importing email us at oilsecurity@mbie.govt.nz