Alcohol licence objections: What grounds can you object on?

In this section Alcohol Licence Objections
On this page

Not sure whether your concerns count as legal grounds for objection? This guide breaks down what the District Licensing Committee can consider – and how to connect those grounds to what is happening in your community.

Why the Grounds for Objection matter

When someone applies for an alcohol licence, the application is considered by the District Licensing Committee (DLC) for the area where the proposed premises is located.

As a member of the community, you have the right to object to a licence application. However, simply disagreeing with an application is not enough on its own. Your objection needs to relate to the matters that the DLC is legally required to consider under the Sale and Supply of Alcohol Act 2012 (the Act).

These matters are set out in section 105 of the Act and are commonly referred to as the grounds for objection.

The grounds cover things such as:

  • The potential for alcohol-related harm
  • Whether the applicant is suitable to hold a licence
  • The proposed trading hours
  • The design and layout of the premises
  • The number of alcohol outlets already operating in the area
  • The impact on the amenity and good order of the community
  • Whether the applicant has appropriate systems, staff, and training to operate responsibly

The DLC must have regard to these matters when deciding whether to grant or decline a licence. Your objection will be stronger when you clearly connect your concerns to one or more of these grounds.

Below we explain each ground in plain language, when it might apply and what it could look like in an objection.

1. The object of the Act

The object of the Sale and Supply of Alcohol Act is to ensure that the sale, supply, and consumption of alcohol is undertaken safely and responsibly and that the harm caused by excessive or inappropriate drinking is minimised.

In plain language: This ground is about whether granting this licence is consistent with the purpose of the Act, which is to reduce alcohol related harm in the community.

You might raise this ground if:

  • The licence would make alcohol significantly more available in an area already experiencing alcohol-related harm
  • There are existing concerns about alcohol-related violence, disorder, or harm in the area
  • The proposed outlet would increase access to alcohol for a community already experiencing high levels of alcohol-related harm
  • The application would add another alcohol outlet in an area where increased alcohol availability is already a concern

Example:

“There are already several bottle shops (off-licences) operating within a short distance of the proposed premises. Our community has experienced ongoing alcohol-related harm including public intoxication and disorder. We are concerned that another outlet could increase the availability of alcohol and contribute to further harm.”

2. The suitability of the applicant

This ground is about whether the applicant is a suitable person to hold an alcohol licence. Licence holders are expected to operate responsibly, comply with the law, and meet their obligations under the Act.

You might raise this ground if you have information about:

  • Previous breaches of alcohol licensing laws (e.g. sale of alcohol to a minor)
  • Repeated failure to comply with licence conditions
  • Previous licence suspensions
  • Concerns about how the applicant has operated other licences
  • A history of irresponsible alcohol sales or management

Example:

“The applicant has previously operated a licensed premises where there were repeated concerns about compliance with licence conditions. We are concerned whether they have demonstrated suitability to hold and operate another licence.”

Tip: This ground should focus on the applicant’s conduct and suitability, rather than opposing the type of business or location.

3. Any relevant Local Alcohol Policy

Your local council may have adopted a Local Alcohol Policy (LAP) that sets local rules for alcohol licensing in your area.

Depending on the council, an LAP may address matters including:

  • Trading hours for licensed premises
  • The location of alcohol outlets
  • The concentration or density of outlets in particular areas
  • Restrictions around sensitive sites like schools, parks, places of worship, or marae
  • Areas where new alcohol outlets are limited

You might raise this ground if:

  • The application appears inconsistent with your council’s LAP

Check your local LAP here.

Example:

“We believe this application is inconsistent with the Local Alcohol Policy because the proposed premises is located within an area where the Local Alcohol Policy places restrictions on the location of new alcohol outlets.”

4. The days and hours of operation

This ground relates to when the applicant wants to sell alcohol. You may be concerned that the proposed trading hours are too long – starting too early and/or closing too late.

You might raise this ground if:

  • The premises would sell alcohol late at night
  • The proposed hours overlap with times when the area experiences more disorder or antisocial behaviour
  • Late-night trading could increase noise, public intoxication, or other disruption
  • The proposed hours are inconsistent with your Local Alcohol Policy

Example:

“The applicant is seeking to sell alcohol until 11pm. Our community already have concerns about noise and antisocial behaviour in the area during the evening. We are concerned that allowing alcohol sales until this time could increase these issues.”

5. The design and layout of the proposed premises

This ground is about the physical design and layout of the premises and whether it supports the safe and responsible sale of alcohol.

You might raise this ground if you have concerns related to:

  • Whether staff can easily see and supervise customers
  • Where alcohol will be displayed
  • The location of entrances and exits
  • How customers will move through the premises
  • Whether the layout could make responsible alcohol management more difficult

Example:

“The proposed alcohol displays are located at the rear of the premises, away from the main checkout area. We are concerned that staff may have limited visibility of customers in this area, making it more difficult to monitor purchases.”

6. The sale of goods other than alcohol, low alcohol refreshments, non-alcohol refreshments and food

This ground considers what else will be sold at the premises alongside alcohol.

This is particularly relevant for off-licences such as supermarkets, where alcohol is sold alongside other goods, including groceries, tobacco or vaping products, and convenience items.

Consider whether the sale of alcohol alongside other products could make alcohol more visible or convenient to purchase.

You might raise this ground if you are concerned that:

  • Alcohol will be highly visible and easily accessible alongside everyday goods
  • The range of other goods sold at the premises could encourage more people to visit the premises, increasing likely alcohol purchases and consumption

Example:

“The proposed premises will sell alcohol alongside everyday grocery and convenience items. We are concerned that this will make alcohol highly visible and easily accessible as part of routine shopping in the community.”

This ground considers whether the premises will provide other services or activities alongside alcohol sales.

This could include:

  • Gambling or gaming
  • Live entertainment
  • Events or other attractions
  • Other activities intended to bring or keep people at the premises

You might raise this ground if you are concerned that:

  • Additional services and activities may encourage longer stays and/or increase alcohol consumption at the premises

Example:

“The premises will provide entertainment alongside alcohol sales. We are concerned that combining these activities could encourage people to remain at the premises for longer periods and increase alcohol consumption.”

8. The effect on the amenity and good order of the locality

This ground is about the potential impact the proposed licence could have on the character, peace, and functioning of the surrounding community.

This could include:

  • Litter
  • Violence
  • Vandalism
  • Noise and/or nuisance
  • Antisocial and/or disorderly behaviour
  • Disruption to nearby homes or businesses

The surrounding environment is also relevant under this ground. For example, the premises may be close to sensitive sites, such as:

  • Schools or early childhood centres
  • Playgrounds or parks
  • Churches
  • Marae
  • Community centres
  • Other community spaces regularly used by whānau and tamariki

You might raise this ground if you are concerned that:

  • The proposed premises could contribute to more noise, litter, and disorder in the surrounding area
  • The sale of alcohol could negatively affect nearby homes, businesses, or community spaces
  • The premises is near a kura, marae, church, playground or park, and you are concerned about the potential impact on people using these spaces
  • The area is already experiencing alcohol-related issues such as public intoxication, violence, vandalism, or antisocial behaviour
  • Increased alcohol availability could worsen existing disruption in the community

Example:

“The proposed premises is close to a primary school and residential homes. There are regular reports of disorderly behaviour and litter in the area. We are concerned that increased alcohol availability could contribute to further disruption for the local community.”

9. The effect of existing licensed premises on the locality

This ground recognises that an area may already be experiencing significant impacts from existing licensed premises.

The question is not simply whether another licence would make things worse. It is also relevant where the area is already significantly affected by existing licences that it is not desirable to add another licence.

You might raise this ground if:

  • There are already a large number of alcohol outlets in the area
  • The community is experiencing significant alcohol-related harm or disruption associated with existing outlets
  • Adding another outlet would contribute to an already concentrated alcohol environment
  • There is evidence that existing outlets are already affecting the amenity and good order of the area

Example:

“There are already several licensed premises operating in this neighbourhood. The community is experiencing ongoing issues with these outlets including noise, disorder, and litter. We are concerned that adding another outlet would further increase the density of alcohol outlets in the area.”

Tip: This ground is important! It provides a way to explain the cumulative impact of alcohol outlets, rather than trying to argue that the new premises alone will create all the harm.

10. Whether the applicant has appropriate systems, staff and training to comply with the law

Licence holders must have appropriate systems in place to ensure alcohol is sold responsibly, including trained staff who can identify intoxicated people, check IDs and follow the law.

You might raise this ground if you have concerns about whether the applicant can:

  • Prevent sales to intoxicated people
  • Prevent sales to people who are underage
  • Check customer ID
  • Manage restricted or supervised areas
  • Comply with licence conditions and legal requirements

Example:

“The application provides limited information about how staff will be trained to identify intoxication and prevent sales to intoxicated customers. We are concerned that the applicant has not demonstrated that appropriate systems and training will be in place.”

Tip: Focus on what the applicant has not demonstrated in their application, rather than making assumptions about how they will operate.

11. For renewal applications: the applicant’s previous conduct

For renewal applications, the DLC must consider the way the applicant has previously sold, supplied, displayed, advertised, or promoted alcohol.

This can include concerns about how the premises have operated in practice, including whether they promoted alcohol responsibly, followed the advertising rules and operated within their licence conditions.

You might raise this ground if you have concerns about:

  • Irresponsible alcohol promotions
  • Advertising or displays that do not comply with the law
  • Previous breaches of licence conditions
  • Repeated issues with the operation of the premises

Example:

“The premises has previously breached its licence conditions, including failing to properly check identification before selling alcohol to a minor. We are concerned about the applicant’s previous compliance with their licence conditions and whether the premises has been operated responsibly.”

Tip: This ground is only applicable for renewal of applications; it does not apply to new licence applications.

How to use these grounds in your objection

You do not need to use all of the grounds in your objection. Focus on the grounds that are relevant to the application and your community’s concerns.

A strong objection should cover the following:

  1. What are you concerned about?
  2. Which grounds do your concerns relate to?
  3. What evidence, experience or information supports your concern?
  4. What impact could the licence have on the community?

You don’t need to be a legal expert to make an objection. Your experience, knowledge, and observations of your community are valuable.

The key is to clearly explain your concern, connect it to the relevant ground for objection, and provide any evidence or examples that support it.