NZ Gift Card Expiry Law: 3-Year Guide for Hospo & Wellness
Picture the Saturday morning rush at your cafe, or a fully booked Friday afternoon at your beauty salon. A customer steps up to the counter, pulls out a crumpled, faded paper gift voucher from two years ago, and asks to spend just $6.50 of a $50 balance. While the queue builds behind them, your staff are left flipping through dog-eared carbon-copy books or scrolling through an ancient spreadsheet, praying they don't accidentally breach consumer law.
Since the Fair Trading (Gift Card Expiry) Amendment Act 2024 came into full force on 16 March 2026, managing vouchers has become a serious legal responsibility for New Zealand hospitality and wellness operators. Every gift card you sell in NZ must now carry a minimum 3-year expiry period, and you must track partial redemptions accurately across that entire 36-month window. If your team gets it wrong, your business risks a Commerce Commission infringement notice of up to $1,000 per offence or, if prosecuted, court fines of up to $10,000 for individuals or $30,000 for companies.
Stopping gift card sales altogether is not the answer. Research from Consumer NZ shows that 77% of New Zealanders regularly receive gift cards, and prior to the law change, 1 in 5 holders were left stuck with an expired card. Just as you maintain strict NZ food hygiene compliance to protect your customers and licence, your checkout needs a watertight gift card system. This guide explains the exact March 16, 2026 gift voucher rules NZ businesses must follow, which promotional vouchers are exempt, and how switching from risky paper certificates to Apple Wallet digital gift cards streamlines your compliance.
What the March 16, 2026 gift voucher rules mean for NZ businesses
Under the statutory text of the Fair Trading (Gift Card Expiry) Amendment Act 2024 (Sections 36WA to 36WC), any gift card or voucher sold to a consumer in New Zealand on or after 16 March 2026 must remain redeemable for at least three years from the date it is sold, unless it has no expiry date at all.
The law applies equally to physical paper certificates, plastic magnetic-stripe cards, and digital e-gift vouchers sent by email or SMS. Whether you run a suburban coffee shop, a busy food truck, a Thai massage clinic, or a boutique hair and beauty salon, if a customer pays for a gift voucher, the 3-year clock starts ticking on the day of purchase.
What happens if you still have a stack of pre-printed cardboard vouchers sitting under your till that say "Valid for 12 months"? Under Section 36WB of the Act, any term or condition that sets an expiry period shorter than three years is legally void. By law, that voucher is automatically treated as expiring three years after the date of sale. Worse still, selling a voucher that displays an unlawful 12-month expiry date is a direct breach of the Fair Trading Act because it misleads the consumer about their legal rights.
What you need to do today:
- Audit your physical counter stock: Open your cash drawer and check every pre-printed gift certificate or envelope in your shop.
- Destroy or amend old 12-month cards: Either shred old paper stock that prints a 1-year expiry, or manually cross out the printed 12-month rule in permanent ink and write the compliant 3-year expiry date before handing it to a customer.
- Check your website footer and checkout emails: Remove any outdated "Vouchers are valid for 6 or 12 months from purchase" clauses from your online store terms and automated email receipts.
- Disclose any fees clearly: The new gift card rules don't ban fees, but any fee must be disclosed clearly and not mislead customers under the Fair Trading Act. The simplest option is to charge no fees on gift cards at all.
The 4-way prominent display checklist (Section 36WC)
One of the strictest Commerce Commission gift card requirements is that you cannot hide the expiry rule inside a dense Terms and Conditions page on your website. Section 36WC mandates that every gift card must have a prominently displayed expiry date notice written clearly on the physical card or digital voucher itself.
According to official enforcement guidance from the Commerce Commission New Zealand, there are only four legal formats you can use to display the expiry date on your vouchers. You can copy and paste any of these four formats directly into your voucher templates:
- The exact expiry date: "Expires: 20 October 2029"
- The month and year of expiry: "Valid until: October 2029" (Note: under the Act, stating a month and year means the card remains valid right up until the final day of that month).
- The issue date plus the validity period (at least 3 years): "Issued: 20 October 2026. Valid for 3 years from issue date."
- No expiry date: "No expiry date" or "Valid until full balance is redeemed."
The Fair Trading Act penalties for gift card non-compliance are steep enough to wipe out months of hard-earned profit. The Commerce Commission can issue an immediate infringement notice of up to $1,000 per offence if your vouchers fail to display a compliant date. As commercial law firm Simpson Grierson notes, serious or repeated breaches prosecuted in court carry fines of up to NZ$10,000 for an individual (such as a sole trader operating a food truck or massage studio) and up to NZ$30,000 for a registered company.
Promotional vs. loyalty voucher expiry rules in NZ: what is exempt?
Does this mean you can no longer run a "30-day winter facial special" or give away a "$10 off your next burger" voucher that expires at the end of the month? Fortunately, no. Understanding promotional versus loyalty voucher expiry rules in NZ is critical so you know when the 3-year rule applies and when you can still set short 30-day or 90-day expiry dates.
As outlined by Business.govt.nz, the 3-year rule only applies to gift cards sold to a consumer, while vouchers automatically generated when a customer reaches a loyalty spend threshold are not treated as a sale and are exempt.
However, there is a major compliance trap that catches many hospitality and wellness owners off guard: bundled bonus cards. According to the Commerce Commission's gift card guidance, which is also highlighted by Retail NZ, the Commission considers "bonus" gift cards given alongside a purchase (for example, "Buy a $100 Christmas restaurant voucher and get a $20 bonus card"), as well as gift cards bought by redeeming loyalty points, to be covered by the mandatory 3-year expiry rule. Because the customer had to pay money (or exchange accrued value) to trigger that bonus card, it is not a genuinely free giveaway.
Use this quick-reference table to keep your promotions compliant:
| Voucher Type (Hospo & Wellness Examples) | Minimum 3-Year Expiry Required? | Why It Is Covered or Exempt |
|---|---|---|
| Standard Paid Gift Card (e.g., $100 dinner voucher or $80 massage card) | YES (3+ Years) | Sold directly to a consumer as a gift or prepaid store credit. |
| Bundled "Bonus" Gift Card (e.g., "Buy a $100 spa voucher, get a $20 bonus card") | YES (3+ Years) | Bundled with a paid purchase; the Commerce Commission treats the bonus card as part of the sale. |
| Automatic Loyalty Reward (e.g., "Spend $150 on coffee, get a $10 reward voucher") | NO (Exempt) | Automatically generated by a customer loyalty programme without a separate purchase. |
| Genuine Promotional Giveaway (e.g., free $15 voucher handed out at a local street market) | NO (Exempt) | Supplied for marketing purposes at zero cost to the customer. |
| Charity & Community Raffle Voucher (e.g., $50 cafe voucher for a local school gala) | NO (Exempt) | Excluded only if the voucher is sold principally to raise funds for a charitable purpose (s36WA(f)). |
| Time-Limited Event Voucher (e.g., voucher for food or drinks at a weekend festival) | NO (Exempt) | Excluded where the card or voucher is only for goods or services available at a time-limited event. |
Actionable Tip: In your POS software, create two distinct categories: name paid cards "Gift Cards" (set to a 3-year or unlimited expiry) and name free marketing coupons "Promotional / Loyalty Rewards". That way, neither your staff nor your customers will ever confuse a 30-day loyalty perk with a 3-year gift card.
Why paper gift certificates are a 3-year liability trap for hospo & wellness
When gift vouchers only lasted 6 or 12 months, a small cafe, food truck, or massage shop could just about survive using a numbered paper voucher book and an Excel sheet. Over a mandatory 36-month period, paper certificates turn into an operational and financial nightmare.
Trying to reconcile three years of unredeemed paper vouchers is just as error-prone as calculating staff pay manually, which is why smart operators ditch the spreadsheet and automate POS workflows before human errors cost them money. Here are the three biggest ways paper vouchers fail under the 2026 rules.
1. The partial redemption nightmare during rush hour
Official guidance from Consumer Protection NZ makes it clear that when a customer does not spend the full amount of their gift card in one visit, they are entitled to redeem the remaining balance on future visits until the card expires.
Think about what happens when someone brings a $100 paper gift voucher to your cafe or food truck and orders an $18 lunch. Over the next three years, they might return nine or ten times to spend $6 on a flat white or $12 on a cabinet toastie. If you rely on paper certificates, your barista has to scribble remaining balances on the back of a soggy piece of cardboard, initial it, and update a back-office spreadsheet mid-rush.
Worse still, unredeemed gift card balances sit on your accounting ledger as a financial liability. If you ever decide to apply for a business loan or sell your venue, messy paper records hurt your bottom line, whereas clean owned POS data boosts your NZ hospitality business valuation by proving exact, auditable gift card liabilities to buyers and accountants.
2. The "service package vs. dollar value" inflation trap for salons & massage clinics
If you own a beauty salon, day spa, or massage clinic selling digital gift cards to NZ clients, the 3-year rule introduces a hidden margin killer: service price inflation.
Suppose you sell a handwritten paper voucher today that says "Gift Voucher: 1x 60-Minute Remedial Massage" for $95. Between 2026 and 2029, your commercial rent, therapist wages, power bills, and essential oil costs will almost certainly rise. By the time the recipient walks in to redeem that voucher in late 2029, your 60-minute massage might cost $125. Because the voucher promised a specific service rather than a dollar amount, you are forced to absorb a $30 loss on that appointment.
Actionable Fix: Stop issuing gift vouchers titled with a specific service or food package. Always issue vouchers with a clear monetary value (for example, a $95 Wellness Gift Card), or state clearly on the voucher that it represents a $95 credit toward any treatment at current menu prices.
3. Lost vouchers and front-of-house disputes
Ask yourself: could you keep a slip of cardboard safe in your wallet, or find a single PDF attachment in your email inbox, for three full years? Most consumers cannot.
According to Consumer Protection NZ, businesses are not legally required to replace lost physical paper vouchers because they function like cash. However, telling a loyal regular that their lost $120 birthday voucher is gone forever creates a terrible customer experience and awkward arguments at your front counter. When you replace paper gift certificates with digital gift cards delivered by email and saved to Apple Wallet or Google Pay, lost voucher disputes become far less common.
How Apple Wallet gift vouchers simplify your 3-year compliance
The smartest way to reduce compliance anxiety is to let your POS system handle the heavy lifting. With modern gift voucher software, NZ hospitality and wellness businesses can issue Apple Wallet gift vouchers that customers save directly to their iPhone (or Google Pay on Android) in a single tap.
Customers hate downloading clunky third-party apps just to check a voucher balance, a trend we explored in our guide on app fatigue in NZ and why web ordering beats cafe apps. Because Apple Wallet is already built into every iPhone, your branded gift card sits right alongside their everyday bank cards.
Here is how Lazygrid's built-in Vouchers & Gift Cards feature (included in the Standard plan at $59/month) supports the requirements of the 2026 law:
- Expiry Date Management: Set expiry dates on your digital gift cards inside Lazygrid so every card you sell meets the 3-year minimum.
- Partial Redemption & Balance Tracking: Staff can redeem part of a gift card at the POS, and Lazygrid keeps track of the remaining balance.
- No Expensive Hardware or Hidden Fees: Unlike traditional POS providers that charge thousands for proprietary terminals and plastic card swipers, or expensive global POS systems, Lazygrid runs on the iPad or iPhone you already own.
- Fast Staff Onboarding: Even weekend casuals can issue and redeem digital gift cards on their first shift, which is another example of how iPad restaurant POS software cuts staff training from days to hours.
4 steps to upgrade your gift card system today
Whether you are figuring out how to start a food truck in NZ, managing a busy neighbourhood salon, or planning a food truck to cafe POS upgrade, transitioning away from paper vouchers is straightforward. Follow this four-step checklist to help your business meet the new rules:
- Retire Non-Compliant Paper Stock Immediately: Pull any pre-printed 6-month or 12-month paper vouchers out of circulation today so a casual staff member doesn't accidentally sell one during a busy shift.
- Create Dollar-Value Digital Denominations: Set up clean, monetary-value e-gift cards that cafe, restaurant, and salon shoppers can easily choose from (such as $25, $50, $100, and $150) inside your POS dashboard. If you run a massage or beauty clinic, price your cards to match your most popular treatments without locking yourself into fixed service titles.
- Add Your E-Gift Card Link Everywhere: Connect your digital gift card checkout to your website, Instagram bio, Facebook page, and Google Business Profile. Letting customers buy and email an Apple Wallet gift card at 10 PM on Christmas Eve or the night before Mother's Day creates effortless upfront cashflow.
- Migrate Remaining Paper Balances at the Counter: When a customer comes in to partially redeem an older paper voucher, enter their remaining balance into your digital POS gift card system and issue a digital gift card. You get to throw the paper slip in the recycling bin, and the customer gets a convenient digital voucher on their phone.
Conclusion
The Fair Trading (Gift Card Expiry) Amendment Act 2024 has permanently changed how hospitality and wellness businesses handle vouchers in New Zealand. Offering a minimum 3-year expiry on gift cards sold in NZ, displaying expiry dates prominently in one of the four legal formats, and tracking partial redemptions down to the cent are now non-negotiable parts of running your checkout.
Hanging onto paper certificate books and manual spreadsheets will only create counter bottlenecks and compliance risks over the next three years. By switching to Apple Wallet gift vouchers that NZ customers can keep right on their phones, you help protect your business from penalties, save your staff hours of admin, and turn gift cards into a reliable year-round revenue stream.
Want to see how easy it is to sell and track compliant digital gift cards on an iPad or iPhone? Explore Lazygrid POS today and discover how our all-in-one hospitality and wellness system helps Kiwi businesses run smoother every day.
Frequently asked questions
Does the 3-year gift card expiry rule apply to vouchers sold before 16 March 2026?
No. The Fair Trading (Gift Card Expiry) Amendment Act 2024 is not retroactive. Any physical or digital gift card sold on or before 15 March 2026 remains subject to the original expiry date stated on the voucher at the time of purchase.
What happens if my cafe or salon accidentally sells an old paper voucher with a 12-month expiry date?
Under Section 36WB of the Act, the 12-month expiry clause is legally void and the gift card automatically defaults to a 3-year expiry period from the date of sale. However, selling a voucher that displays a 12-month expiry date still breaches the Fair Trading Act and exposes your business to enforcement action from the Commerce Commission New Zealand.
Do I have to give cash change if a customer only spends part of their gift voucher?
No. You are not legally required to give cash change or cash refunds on unused gift card balances unless your own store policy promises to do so. However, you must allow the customer to carry over and spend the remaining balance on future visits until the 3-year expiry date passes.
Are "Buy $100, Get a $20 Bonus Voucher" promotions exempt from the 3-year rule?
No. Because the customer had to make a qualifying purchase to receive the $20 bonus card, the Commerce Commission treats the bonus voucher as part of a sale rather than a genuinely free promotional giveaway. Both the $100 card and the $20 bonus card must carry a minimum 3-year expiry.
Can I charge a fee to maintain a gift card balance over the 3 years?
The gift card expiry rules don't specifically ban fees, but any fee must be disclosed clearly and not mislead customers under the Fair Trading Act. Many businesses choose to charge none to avoid disputes.
What are the fines for breaching the NZ gift card expiry laws?
The Commerce Commission can issue an immediate infringement notice of up to $1,000 per offence. For serious or systemic breaches prosecuted in court, court fines reach up to $10,000 for an individual (such as a sole trader) and up to $30,000 for a body corporate.