Close this search box.

Is Bigger Better? Survey on Child Numbers

Search Entire Website
school bags

Child Numbers.
“Good Common Sense or Putting Children at Risk?  A Report on Reactions to a Change in Regulation for NZ Early Childhood Centres to Increase Child Numbers.”
A Report prepared by Dr Sarah Alexander, March 24, 2011. 


1) What has Happened
The Ministry of Education has signalled that the current maximum number of 50 children (from birth to 6 yrs) or 25 infants (birth to 2 years) per each early childhood centre licence will be increased to 150 children or 75 infants from the 1st July this year.

This is stated on the Ministry website as a change that will benefit 460 of the approximately 3,089 early childhood centres and hospital based services which currently hold more than one licence to care for groups of more than 50 children or 25 under 2s on the same site. It will also allow for existing early childhood centre providers to apply to increase the number of children they are licensed to have, space permitting. (The number comes from the 1 July 2010 Ministry of Education annual census of early childhood services. It includes licensed childcare and kindergarten services along with hospital based education and care, and excludes the correspondence school, parent-led services, and home-based/family daycare services.)

2) Why it has Happened
Two key reasons seem to be behind the change in regulation. First, in 2008 the National Party promised if elected into government to remove the requirement for centres with more than 50 children to have a second licence, and thus do away with the duplication of paper-work and save on compliance costs.

And second, increasing the licence size of early childhood centres will lift the capacity of the sector to provide more childcare for higher child numbers at a potentially lower price than currently provided, and support the work-testing requirements recommended by the Government’s Welfare Working Group.

3) What the Issue About Child Numbers Is
In NZ there are no regulations specifying a limit on the number of children in each group within an early childhood facility. So the centre size, or ‘licence size’, is also the maximum number of children that can be together within a building or room as a group.

A new entrant school class size is typically up to about 18, 5-year-olds. In an early childhood centre a 2, 3, 4 or 5 year old can currently experience a class size of up to 50 children. And soon a preschooler may be one in a group of 150 children.  The minimum staff to child ratios in teacher-led early childhood services are better than in primary schools, though this might not mitigate against the bigger numbers in early childhood centres.

In many countries overseas, centres that have group sizes of more than 15 – 18 infants are usually regarded as being of low quality. In NZ we currently permit 25 infants to be cared for together. And soon a child under 2 years of age may be one in a group of 75 children.  This contrasts starkly with the newly released report of the Commissioner for Children, recommending a reduction in group size to a maximum of 8 for children under 2 years

The Ministry of Education has said that the “amended regulations will allow the Secretary for Education to set special conditions on a licence to limit the use of defined activity spaces to an appropriate number of children” (Ministry of Education, 16 March 2011).  There is no indication if   existing conditions for licensing will be maintained  i.e. if each group of 50 children (within the 150) or each group of 25 infants (within the 75) will continue to have separate indoor and outdoor play space,  eating and sleeping spaces, and washroom and toilet/nappy changing facilities, along with dedicated teachers.

Existing services will increase child numbers (space permitting), and we could see the licensing of  ‘mega’ early childhood facilities with group sizes of 150 children and staff, or 75 infants and staff, all sharing the same space. 

What we don’t know is whether there is support for this regulation change in the early childhood sector and amongst all stakeholders, and importantly, what the risks and benefits might be.  So we conducted a survey.

4) About the Survey
An online random survey of 450 people was conducted shortly after a notice announcing the regulation change was placed on the Ministry of Education website.

To have this number of people responding in a matter of days was a phenomenal response, particularly as this was at a time when Christchurch and the effects of the latest large earthquake consumed our nation and our news. Being asked to say who they were and give their contact details on the survey form did not seem to mitigate the number and intensity of responses received.

Respondents included parents, teachers, employers, health professionals, child advocates, early childhood researchers, and other interested people.

This report presents the findings of the survey, along with recommendations and ideas arising from the feedback received. 

5)  Overall Findings
Our online survey of 450 people has found little support for an education regulation amendment to allow early childhood service providers to increase child numbers.

There was general disbelief with the claim on the Ministry of Education website that the quality of early childhood care and education would not be affected by an increase in child numbers.

The 91% opposed to the change talked about ‘crowd control’, ‘too many people to get to know’, children feeling ‘overwhelmed’ and being ‘over-stimulated’, ‘being just a number’, ‘places where no one knows your name’,  ‘increased stress for children and adults’, ‘institutionalising children’, ‘loss of whanau or family feeling’, and ‘noisy’ and ‘unhealthy’ environments.

A small percentage (9%) of respondents supported an increase in child numbers through a regulation change for licence size. Their reasons included that it would save on compliance costs, reduce paperwork, and save time. The efficiencies would likely result in increased revenue at a time when government appeared to be seeking to cut back on centre funding and it would help services to make more childcare places available.  

The majority of the 9% who supported the change were involved with a multi-licensed service (services that currently have more than 1 licence/50 children). This finding was not surprising.

However when the responses of these people were separately analysed it was found that of the 130 respondents from multi-licenced services 103 (79%) were opposed to the change. This is a high percentage of opposition from people involved with services which potentially stand to benefit financially from the regulation change.  (67 of the 130 were employers/owners of centres with multiple licences, including national chains, and others were in leadership roles e.g. managers, chief executives, or management boards).

crowd of children

Those against an increase in licence size were concerned that ‘quantity’ (paving the way for current and future services to cater for larger numbers of children) was being put ahead of ‘quality’ (by not making changes that would help to safeguard against the effects on children of increased centre size). Possible safeguards could include: setting maximum group sizes, requiring the use of separate spaces for each group of children, requiring children to be cared for in family or mixed-age groups, increasing the percentage of qualified teachers, and/or reducing the teacher-child ratio. Without safeguards to moderate the effects of being in a larger group, children who might already be socially and educationally at risk might be disadvantaged further.

Feedback on what impact an increase in licence size would specifically have on children indicates it is expected to have serious implications, especially on children’s health, emotional and social development, and their learning.

Though this survey did not include a question on what the impact on staff would be, 43 respondents said that staff dealing with a larger number of children would struggle to cope, resulting in higher stress levels, burnout and poorer health. There was concern it could become harder for larger centres to recruit and retain qualified staff, which in turn would impact on children’s care and learning.

Only 21 out of the 450 respondents expected that the change would have no impact on children or that larger service size would advantage children. An additional 17 welcomed an increase in licence number, providing other standards remained in place e.g. for qualified teachers and ratios.  

As a result of the regulation change it was expected that more commercial larger-scale services would come to dominate the provision of early childhood education in NZ. Larger services were expected to increase their profit margins or offer lower fees. They would be in a stronger position to compete with smaller centres for child enrolments, resulting in less community based early childhood education, and fewer choices for families. Smaller centres could market themselves and come to be valued as ‘boutique’ services, in hot demand by families, but out-of –the-reach of low-income families.

Asked if they would support the introduction of new rules for maximum group sizes (the number of children to be cared for within groups within the licence number of the service) 81% of respondents said ‘yes’. They believed this to be essential if the maximum licence number was going to be increased. But many of their comments also suggested that introducing new requirements for group sizes within centres would not totally reduce the disadvantages for children of being one within a larger number of children and adults. 

Of the 19% who replied ‘no’ or were undecided about whether there should be new rules for maximum group sizes, most said this was unnecessary as their service already practised having smaller group sizes within the licence size, or other indicators of quality were more important such as ratios. Some thought that it should be up to individual centres whether and how to group children, or that it would be too costly to implement (e.g. if it meant a qualified teacher needed to be with each group of infants rather than the qualified teachers being spread throughout the centre).

6) Conclusions and Recommendations
This report reveals two contrasting views regarding the regulation amendment to increase centre licence size.  The first view is a business operational one of why not make the regulation change as it could save early childhood providers money and lift the capacity of the sector to provide more childcare. 

The second view can perhaps be summarised as a human view on the implications of the seemingly simple regulation change and from this perspective there is a lot of worry that the change will do much more harm than good.

Moreover it might not be a good look for NZ on the international stage to have group sizes in early childhood education that are the same as the centre size, and therefore probably the largest of any country that regulates the quality of childcare/early education. A question of children’s right to quality early childhood education and care and how the regulation change would/would not support this right was also raised in the feedback. As one respondent stated:

This change is not in the best interests of young children and babies. This will undermine quality care and education and possibly contravenes the United Nations Convention of the Rights of the Child document and children’s rights. NZ is currently a world leader in quality ECE and these changes are an insult to NZ’s reputation.

The NZ Treasury along with the government have identified that a deficiency in the provision of early childhood education is penetration through to lower socio-economic groups. According to the NZ Treasury:

An important challenge at present is to ensure that the strains of this broad growth, such as capacity constraints and teacher supply shortages, do not fall disproportionately on children from disadvantaged backgrounds (Putting Productivity First, NZ Treasury Paper, April 2008, pp. 19 – 20)

Will granting licences for up to 150 children in a centre instead of the current 50 advantage children from disadvantaged backgrounds?  The results of this survey suggest the regulation change will fall “disproportionately on children from disadvantaged backgrounds”.

Children who are already most disadvantaged, most at risk educationally and in health, and most needing the best care, will be the ones who are most likely to be disadvantaged. Larger services will easily be able to undercut smaller services on price and will offer more places. Greater numbers of children bring greater risks for  diseases spreading, infections, high noise levels and hearing loss, children not getting personal attention, teaching the group rather than the child, less parental involvement and family contact, and children’s individual needs not being picked up on and met according to survey respondents.

Maybe there is not a need for a change in the regulations for licence size? Perhaps the problem of paperwork and bureaucracy stemming from large services having more than one licence per each group of 50 children, could be addressed in another way? Then group sizes at a maximum of 50 in each centre space within a service for preschoolers or 25 for under 2s could be retained, or until such time as regulations are developed for group size and conditions are developed to help to mitigate against the potential risks for children of larger scale ECE provision. 


What has Happened

On Friday 4th March the Ministry of Education published a notice online announcing that from the 1st of July 2011 early childhood centres including hospital education and care services would be able to apply to increase the number of children they currently have, space permitting and other standards being in place, by three times the current maximum number.

The notice stated that the maximum allowable number of children per licence attending a centre would increase from 25 to 75 under-two-year olds. In services with mixed ages (0 – 6 yr olds) and preschoolers only it would increase from 50 to 150 children.  The regulation change would apply to current 420 multi-licence services and other services which have “capacity to cater for more than 50 child places will be able to apply to amend their current licence to increase their number of licensed child places rather than apply for an additional licence”. The increase was explained as:

  1. an administrative tidying up to save paperwork and time for the approximately 460 early childhood services operators with more than one centre licence on the same site, and
  2. opening up the possibility for  other services to increase their enrolment numbers if they have the capacity.

It was stated that the regulation change would “in no way compromise the quality of education and care”.  

Services have to ensure that they have environments appropriate to the number of children for which they seek a licence.

Ministry of Education permission for services to amend their licence to enrol more than 50 children will only be granted when certain conditions are met. These include:

  • they have the appropriate space and facilities;
  • they meet all the health, safety, and quality requirements;
  • they meet all staffing requirements; and
  • they are located on one (single) site.  (Ministry of Education, 16/3/2011)

This amendment to the early childhood regulations to increase licence size has not been officially gazetted yet. There is therefore a short window of opportunity to discuss and have open debate on the proposed change so we can be sure that this regulation change is a good one for infants and young children, for the early childhood sector, and for our society.

After the  maximum licence size for early childhood centres is increased will it be possible for any government to subsequently reverse the change or to bring in new requirements to limit the number of children sharing the same spaces for eating, sleeping, playing, etc together?  The answer is anything is possible, but probably any government would find it difficult to ask early childhood services in the future to reduce the number of children in their facilities.

Operational guidelines are being developed to implement the increase in licence size according to the Ministry and it may be, though it is not explicitly stated, that these guidelines will be the mechanism by which it will be ensured quality is not compromised by quantity. 

For as long as there has been regulation for childcare centres 50 preschoolers and 25 under 2s have been the maximum centre licence sizes in NZ. Traditionally a centre was considered to be a large one if it was licensed for 50 children. Over recent years many more services that hold multiple licences for two or more groups of up to 50 children on the same site have opened and these now mostly commercial/private services are considered to be the new large centres.

The change in regulation caught nearly everyone in the early childhood sector and families by surprise, including hospital-based services which will be directly affected also. It was a surprise because of the timing of the announcement and a lack of consultation with all sector groups, when everyone’s minds were on what had happened in Christchurch. Also the change was announced prior to the report of the Government’s Taskforce on Early Childhood Education, due to be released in early April.

Why it Happened 

Underpinning government policy in early childhood education is a belief that early childhood education can lift the skill and intellectual capability of our population. Thus government is keen to improve the quality of early education and target ECE funding to support children who are socially and economically most at-risk:

Human capital and skill formation is a cumulative process over the life course. There is increasingly strong evidence that the greatest gains over the long term will come from improving the quality of education in the early years, and from targeting support to disadvantaged and at-risk children. New Zealand has high rates of participation in early childhood education both by international comparison and compared to historic levels within New Zealand. The sector is seeing rapid growth both in hours of participation and in quality standards. An important challenge at present is to ensure that the strains of this broad growth, such as capacity constraints and teacher supply shortages, do not fall disproportionately on children from disadvantaged backgrounds (Putting Productivity First, NZ Treasury Paper, April 2008, pp. 19 – 20)

Early childhood education is also important to the government because of the link between the availability and affordability of childcare and parents participation in paid work. Recommendations of the Government’s Welfare Working Group Report (Feb 2011) included requiring:

  • single parents to look for 20 hours work a week once their youngest child is three and 30 hours a week when the youngest turns six;
  • women who had more children when they were already on the benefit to return to paid work when the baby is 14 weeks old.

New work testing requirements as suggested in the Welfare Working Group Report will require an increase in government funding of early childhood education. Policy will need to be put in place to increase the availability of childcare places.

My Key said it was too early to detail childcare plans, but:

“If we are seriously going to have an expectation that a young mum is going to get off the DPB and into the workforce, even on a part-time basis, we are also going to have to make sure the child is in a safe environment and is cared for and that it is cost effective” (Childcare Carrot in Benefit Reforms, article by Tracy Watkins, 10 Feb 2011)

Changing the early childhood education regulations to enable early childhood centres to take in more children will likely facilitate the growth of larger childcare services that have economies of scale and can offer cheaper childcare. This could give more low-income families access to ECE and fits in with what this government wants to achieve. The regulation amendment is a logical move therefore and can be understood in this context.

Beyond the factors that underpin government policy in early childhood education is a pragmatic concern to reduce bureaucracy and remove unnecessary compliance costs across all sectors. The National Party in government is fulfilling a promise it made in opposition when stating a commitment to:

  • Check for any instances of over-regulation, allow commonsense to prevail, iron out some of the senseless rules e.g. current requirement for a 2nd licence for over 50 children.
  • Reducing what is perceived to be over-regulation may be argued by the government to be a higher priority than fulfilling promises to improve standards for children, such as:
  • Ensure that, after 2012, sessions for the under-twos in teacher-led early childhood centres are staffed by at least 50% qualified teachers. 
  • Reduce the adult-child ratio from 1 adult to 5 infants to 1 adult to 4 infants.

Also we have yet to see changes in early childhood policy and funding arrangements that would open up more choice for families and enable families to spend more time with their children (with the exception that the government has extended 20 hours ECE funding to parent-led services Playcentre and Te Kohanga Reo),

Previous Ministry Consultation on Increasing Child Numbers

A group is two or more children who share, or spend time in, the same activity areas for the majority of their time in a service each day (Ministry of Education definition of group size)

The Ministry of Education acknowledges in earlier documentation that NZ regulates only for centre size and not for group size. Therefore group size is the same as centre size and it is left up to early childhood service operators whether children are taught and cared for in smaller groups than the centre size. The buildings purchased, and what is built either makes or constrains the possibilities for group size being less than centre size. In open plan buildings for example, more often than not all the children share the same spaces, teachers, facilities etc. 

At the time of the ECE Regulatory Review 2004, the Ministry suggested that what was needed was “a shift from licence size and group size being treated as one and the same thing, to separate regulation to provide for small group sizes in centres whatever their licence size”. It cited the NZ early childhood curriculum document Te Whariki which said “infants should not be exposed to too many new faces or situations.”

Feedback was asked on the following proposal to introduce a new regulation for group size:

  • 12 would be the maximum number of children under 1 year of age
  • 20 would be the maximum number of children aged between 1 and 2 years
  • 30  would be the maximum number of children aged 3 years and older

Of the submissions received by the Ministry from the sector and other interested parties, the spilt between those who agreed (34%) and those who disagreed (38%) was quite close. This was a difficult question to ask for agreement on because it not only asked about the idea of introducing a regulation for group size, but it was also asking people to agree on the introduction of a new age band for 1 to 2 year olds, as well as the maximum number of children in each age-based group size.

At the time of the 2008 ECE Regulations Review in answer to a question of whether government should regulate for maximum centre size, the Ministry received 275 responses in support of regulating maximum centre size and 78 responses against.

In the ECE 2008 regulations review summary report on consultation it is stated in relation to  feedback received from parents consultation meetings that support for the idea of  bigger being better was not found. What parents wanted was for early childhood services to be places where everyone knew their child’s name:

Overall parents felt there should be regulations for maximum centre size and that the maximum centre size should ideally be between 30 and 50 children at any one time. Despite adult-child ratios, parents felt that in smaller centres all staff would be familiar with their child and more able to offer one-on-one attention. Parents expressed concern about the potential of ‘battery processing’ in larger centres.

Parents said that multisite licences should not be provided and that while some of the licensing requirements are transferable (e.g. enrolment policies) and could be used for multisite providers during the licensing process, each physical site should be licensed individually to ensure that it meets requirements.

The Ministry of Education has allowed services to take out more than one licence to have more than 50 children. A large service can operate ‘separate’  centres on the same site with up to 50 children each with a ‘person responsible’ for overseeing each ‘centre group’.

In the ECE regulatory review 2004 references document the Ministry stated that it foresaw a time when all teachers would be registered and there would therefore not be a need to regulate for centre size, only for group size. 

So far, New Zealand has allowed larger centres to develop by issuing them with multiple licences. In this way a large service may, for the purposes of licensing, in fact be two or three ‘separate’ centres. This method has the benefit of ensuring that there are several qualified teachers (Persons Responsible) in a very large centre. In 2012, when all teachers are registered, this necessity will be removed and there will be little benefit in continuing to limit centre size. To improve quality for children, the focus of regulation should shift to group size (ECE regulatory review: 2004 references document)  

Note that a target to achieve 100% qualified registered teachers in teacher-led services has been changed by the present Government to 80% by 2012.


Method and Participants

An online survey of opinion about the proposed change in regulation was conducted by ChildForum.

The responses came in very quickly with 400 received within just a couple of days. It was decided to close the survey after the first 450 responses were received simply as this was a round number and more importantly because as more responses were received the results were not changing.

Respondents had to supply their name and contact details. A good cross-section of people responded from across various early childhood organisations, including service owners and managers, parents, teachers, teacher educators and researchers, child health professionals, ECE association representatives, and child advocates.

A range of people with different interests and levels of involvements in early childhood education and care replied to the survey.

The majority of the 450 respondents were early childhood managers or employers (38%) and employees/teachers/caregivers (37%). Nineteen percent indicated that their interest was as a parent and 18% as a researcher or tertiary educator.  

Of the 11% other, these people included consultants, child advocates, national association presidents and CEO’s, parenting programme providers, primary school teachers, health (Plunket nurses, midwives, and child health service rep), students, and retired/or ex- teachers and employers.

Quite a high proportion of responses to the survey were received from people involved in services with multiple licences (i.e. groups of more than 50 children at their centre) relative to the number of single licence services in NZ. Thus the results will contain a bias toward the views of people associated with multiple licence centres.

Twenty-nine percent or 130 of survey respondents came from multi-licence centres. The Ministry of Education estimates that currently 460 ECE services across the country hold multiple licences.

The Results

Support for Increasing Child Numbers

Support for increasing the licence size was low with 91% (406) against and 9% (39%) for it. Six respondents were undecided or skipped the question

One respondent recorded a vote for and a vote against the regulation change for the following reasons:

Can I put kind of? I’m not so keen on the babies. But having one licence for our three classrooms would be so much less paper work. I was more comfortable when I thought it was going to be 100.  But 150 – so long as each group has its own base and constant teachers, should work as well.

The majority of the 39 respondents who voted for supporting the regulation change were people who were involved with a service that had more than 50 children and therefore more than one centre licence. Most considered it would be ‘business as usual’ and was nothing that anyone should be concerned about. But amongst some of these people there were concerns expressed about the new licence size becoming the new group size (see Section 1.1 below).

More respondents associated with a service that currently holds more than one licence (i.e. a multi-licence service) voted against the regulation change (80%, 103 multi-licence respondents) than voted for it (21%, 27 multi-licence respondents) as outlined below in Sections 1.1. and 1.3. 

Reasons given by multi-licence respondents for supporting increase

Of the respondents who supported increasing licence size the majority (27 out of 39) were involved in centres that had multiple licences for more than 50 children. 

While 8.8% of respondents overall supported the change in regulation, 21% of respondents involved in a multi-licence service supported the regulation amendment. In other words, amongst the respondents who were involved in multi-licence services there was a higher level of support for the regulation change than across all of the respondents.  Multi-licence respondents’ reasons as to why they supported an increase in licence size included that it would:

  • Bring some common sense into regulations,
  • Bring in more flexibility for staffing and staffing duty allocation,
  • Decrease costs of compliance and auditing, and
  • Recognise the fact that services could already have more than 50 children but just had to have separate licences.

a) Bring some common sense into regulations, e.g.

Thank heavens for some common sense finally!

b) Bring in more flexibility for staffing and staffing duty allocation, e.g.

It will reduce unnecessary cost and complex qualified staff movement and admin problems. It will also help improve service and care in bigger centres. 

More flexibility with staffing and outside play areas.

c) Decrease costs of compliance and auditing, e.g.

I think it will decrease costs of compliance for my business and also the government in auditing facets of this service. It will enable me to be more responsive to the very likely continuing eroding of funding.

We have always had two licences (50 each) and these have been split into two classrooms each – 25 children per classroom. A few years ago we were contacted by the MOE which said it should not have approved our plan as one school with one (very large) playground and now wanted us to rectify that mistake through putting up a fence that ran through the middle of our u-shape, splitting our school in two. The effects of this decision were not in the interests of quality but rather an adherence to a rule which made no sense in this instance. In addition, the two licences have meant that we have had to do duplicate paperwork – including staff rosters, funding forms and children’s enrolment and sign-in sheets if the children have changed sides of the building ) from one licence to the other) for anything. Our software programme struggled to cope with this so some of it had to be done manually. The change in ruling will not affect our quality but will reduce our administrative burden.

Our service is in one building, with children divided in 6 separate playrooms under three separate licences, which for us simply creates triple the paperwork. Three Licensing visits, three ERO audits, three of everything when one of everything would suffice. This change makes sense for a centre such as ours.

d) Recognise the fact that services could already have more than 50 children and now there would be opportunity to capitalise financially on this, e.g. 

The loop hole is you can have 2 or 3 licences already. By moving children around in the same building you can increase Ministry of Education funding. = Big centres earn more from MoE

Amongst the multi-licence service respondents who indicated support for the regulation change some held reservations about the change or indicated that they agreed with it reluctantly. The main issue was the potential for licence size to be the maximum group size within a centre. For example:

I do not agree with having larger numbers of children in either the over or under twos. Would like to see some restrictions around group size. However I have two licences on one property and allowing this to be combined would make things much easier for things like transition, administration costs etc.

Removing the paperwork involved with multi-licences is a big step forward. Building centres which have a group size of 150 would not be desirable.

Reasons given by other respondents for supporting increase

Twelve respondents not currently associated with a multi-licence service supported increasing the licence size. Their reasons included that it would:

  • Increase the supply of childcare places in services, and
  • Recognise the larger number of children some centres already had and would not affect current practices. 

a) Increase the supply of childcare places in services, e.g.

Allows centres to meet the needs of their community subject to facilities being available.

Space e.g. if a centre was licensed for 50, if they had the floor space, they could go over 50 on a day/session to enable them enroll a child full time if required rather than wait for all sessions to become available.

b) Recognise the larger number of children some centres already had and not affect current practices, e.g.

As I understand it, it was already possible to have this many children on one site, provided the centre had multiple licences.

Current licence size doesn’t work in practice – i.e. multi-licence centres, so why bother with a redundant regulation that just imposes more paperwork/admin.

I don’t understand why 50 was the magic number if it could be overcome by holding multiple licences.

Numbers isn’t the issue. Quality and management is.

Again though amongst this group of respondents some also expressed reservations about increasing licence size in the absence of any regulation for group size. 

The licence covers the amount of children it does not say that all those children are in one space. Group sizes should take care of that. This only helps cluster centres. I don’t think there should be any one centre with more that 25 under twos in it.

I agree with being able to have 150 children on a licence but there needs to be a restriction on the number of children in a group.

Multi-licence respondent reasons for not supporting  

Seventy-Nine percent of respondents (103 out of 130)  who indicated they were currently involved with a service that held more than one licence were against the change in regulation to increase licence size. Their reasons included that it:

  • Is a money and funding issue,
  • Favoured a certain style and ownership of early childhood education/childcare,
  • Could have long-term costs,
  • Runs counter to what the early childhood sector aspires to achieve in providing quality,
  • Was a decision made without consultation, and
  • Meant the creation of early childhood environments that most MPs and adults would themselves not like to be in.

a)  A money and funding issue, e.g.

Puts the needs of society (i.e. economic considerations) way above those of young children. Business model (economies of scale).

Taking away from one area of ECE like 100% qualified staff and increasing number for children for centres is putting the financial increase on parents and Govt contributes nothing.

It’s all about the dollars isn’t it? And for government to say quality won’t be affected – rubbish. They’ve also allowed reduced qualified staff (80%). So this means there’s less money spent on qualified staff, and more children allowed to be herded into inadequate spaces – no-one has talked about the teacher-child ration either… has that altered???

I am strongly against (NO), this huge number, it is like a baby farm instead of “nurturing and caring”. The value that I see here is money not the WELFARE OR WELLBEING OF THE INDIVIDUAL CHILD!!

b) Favoured a certain style and ownership of early childhood education/childcare, e.g.

No, this does not allow for children to enjoy an education, it is making them into cattle, to be moved around and to earn money. It will also mean more untrained people will be working in these centres.

It will allow businesses to set up childcare centres where children will be seen purely as commodities. There are already centres like this. It reminds me of battery chickens.

The proposed change to regulations is going to give preference to those business groups which are well established. The likelihood of the centre on every corner in the style of the “kentucky fried daycare’ is a potential hazard from the regulatory change.

Welcome to a McChildcare regime of supersized unhealthy childcare centres served to you by untrained underpaid babysitters. All literature and research shows that smaller group care is better than larger centres. Smaller sized childcare centres means less staff turnover, less noise pollution, better standards of care, better work ethic, better relationships with whanau and community and therefore better sense of belonging and well-being for children. How are they going to staff these massive centres, in terms of getting enough quality and qualified teachers and managers?

c)  Could have long-term costs, e.g.

Why do we need to change something which works well? If it is money it will get back to you. Children will be neglected or worse; so still have to pay out for accidents etc. So it is not good for the future.

I feel the quality of education and care will be seriously compromised; children do not cope well in large groups; over stimulation, lost in the large numbers, noise level are all detrimental to young children. With numbers at this size the effects will be felt in later years with lack of concentration, empathy, self confidence and self awareness.

Are we wanting parents of the future to not know how to parent and simply put their children into care the second they can?? Or would more hands on parenting mean that the next generation learn how to parent better and value their children’s early learning and therefore become better at it. This would have effects in the long run of hopefully having a stronger family based community which would then lead to less crime and so forth….

d)  The change runs counter to what the early childhood sector aspires to achieve in providing quality, e.g.

Torments the quality the ECE sector has been trying to achieve in the last 30 years

It continues to worry me that the Government insists on focusing its efforts on quantity rather than quality.

Quality cannot be guaranteed regardless of what the government says. It is hard enough to ensure quality with current ratios.

Absolutely terrible for children. Noise levels will be horrendous. Children’s hearing will be damaged. Unhealthy; unhygienic; bad bad bad.

How would you remember children’s names, let alone develop relationships with individual children. It would be very difficult to provide for individual children’s strengths and interests.

I already work in a centre that has 50 Over 2’s and 25 Under 2’s and feel it is too large to handle on one licence.

Smaller operations allow for families and teachers to form stronger relationships and work together for the best interests of each child. A big business model is not necessary, and in my view  it is dangerous.

Children in the numbers suggested is leading to institutionalisation – something other sectors of the  ‘people’ industry have moved away from.

The current regulations ensure a group size that though not ideal, provides an environment where relationships can be developed and children can investigate their interests in a reasonably relaxed way. There have been no issues for our centre with the current system of multiple licences – it is not a problem. One person responsible for 50 children?  This can not work in relation to quality!

150 children (over 2’s) is not an agreeable number for one licence. It will open up possibilities for masses of children to be catered for in large areas and a lack of personal one-to-one care.

e)  The change was made undemocratically without consultation, e.g.

I don’t agree with the process taken around this change.  There was no visible consultation with the sector, no discussion, just changes to Ministry of Education website and a letter. My biggest concern is the impact it will have on under 2s. Group size is a concern.

It is unethical and unhealthy to have such an increase without greater thought and discussion.

Lack of consultation with the people who are affected by change- there are many issues to consider – some site specific.

f)  It would create early childhood environments that most Members of Parliament and adults would not like to be in, e.g.

The group size is too big to provide optimum learning and care. Research shows this and so does instinct. No adult would enjoy going each day to a party with 150 people and the organisers (teachers) would find it difficult working with such a large group.

It is totally disrespectful and humanly inappropriate to have this many children in one space it reminds me of baby-farming and it would be like an adult being at a full time party all week.

Greater numbers of children will put a lot of pressure on teachers and it will affect the children’s well-being and the teacher’s. The quality of education and care will drop. Get Government MPs in to care for this number of children and see how they feel.

The following explanation for not supporting the regulation change provided by the manager/employer of a multi-licence service sums up well many of the concerns:   

1. There has not been consultation with all Early Childhood Services in New Zealand. 2. There are not criteria or requirements to have smaller groups 3. Big is not better 4. Research proves smaller groups are better.

Why other respondents did not support an increase in licence size

Amongst other respondents the reasons given for not supporting a change in regulation echoed all the points made by multi-licence respondents (as reported in Section 1.3.) and more. A great deal of concern was expressed for the wellbeing of children – and adults – in services with large numbers.

These concerns included the following:

  • Environments with large group size do not suit young children,
  • The challenge of trying to meet young children’s needs in a centre with larger group size, and
  • A lack of safeguards to ensure children’s welfare and quality of care and education.

a) Environments with large group size do not suit young children, e.g.

No primary or high school class has more than 50 children why should ECE!!

Very overpowering for a child starting a group. Schools etc are trying to reduce their class sizes to below 30 and these ECE groups will be twice the number with younger children. Where is the logic!

Too big, too early to expose little children to such “institutionalised” environments. Big is not always the best!

Centres with 150 children and up to 75 babies are not quality childcare – they are zoo’s!

These numbers are far too high. The children will be experiencing an environment which is far removed from one where they are a part of the local community.

Many children are likely to feel overwhelmed, lost, and alienated from what should be an extension of a ‘home setting’.

Children require small, warm, nurturing environments where they can learn to know all the others with them (adults and children) and be known by the others. This can not happen in large groups and will damage children’s ability to participate in real community life later on.

The problem with centres of this size is that the number of relationships, both adult and child that each child has to negotiate, expands exponentially.

The idea of mass provision for children and infants in early childhood means they are more likely to be treated in an impersonal manner. How will these provisions demonstrate the care we have for our children in New Zealand?

b) The challenge of trying to meet young children’s needs in a centre with larger group size, e.g.

So many centres in city areas already have minimal outdoor spaces for kids to run and play. How on earth can more kids be packed in to centres without compromising the outdoor space?

The number of children in a centre can be seriously influenced by individual children’s behaviour / needs at any one time. Larger numbers of children can be testing for children as well as adults.

I find it is already hard to adequately look after 25 children under 2. It is possible to have more but you wouldn’t be doing the children any favours – it is detrimental for their health and well being.

Smaller numbers mean more attention to each child’s needs and teachers can respond appropriately to group dynamics and differences in gender, age, temperament, special need etc (as a mother would with her family) . Doing this, while having fun, with a large group of children gets more difficult.

This has to be a safety hazard.

Babies and young children are much more susceptible to catching infections and diseases.  Until their immune systems mature children’s exposure to large groups of people should be reduced.

My experience working in and visiting a range of centres is that smaller group sizes create better opportunities for more reciprocal and trusting interactions between children, staff and families.

The quality of relationships for young children in out of home care, especially for infants and U2s is critical. Small group size is widely recognised as a key factor which can mitigate the potential risks to attachment relationships and emotional wellbeing.

c) A lack of safeguards to ensure children’s welfare and quality of care and education

Raised noise and stress levels for children and staff with no accompanying assurance that group size will be reduced, or staff ratios improved.

Group size has a significant effect on quality, it appears this is often overlooked and ratios are focused on. In my experience large group size tends to result in a factory type mentality where routine and procedure impacts badly on outcomes for children.

75 under twos is far too many to have under the same licence. Similarly, 150 children is also too many. There are no new regulations for group size to accompany the change in licence size i.e. how many babies in the one space will be permitted? 

There is a need for early childhood teachers.  The majority will need to be qualified, yet we are lacking teachers now

Views from other countries

For readers of this survey report, below is a sample of the range of responses we received from other countries about the NZ regulation change. Most thought that NZ should not be considering a regulation change such as this. There is some suggestion that other standards for centres are important also, for example the Canadian respondent indicated that increased licence size can be accepted and welcomed for the benefits that a large organisation can bring, if there are also specified maximum group sizes.

Australia – leading early childhood academic

New Zealand has led the developed world for many years with their early childhood practices. I am deeply concerned that the government may no longer consider this to be a priority. By increasing the licence size it is likely that the children will receive inadequate levels of care and education, leading to heightened levels of anxiety and decreased opportunities to develop appropriately. Families and the community will be disadvantaged by lack of personalised care.

Australia – Early childhood service manager

Believe it is likely to reduce the consistency of staff available to infants. There will be too much temptation to fill gaps with staff from other rooms. Even if ratios are preserved are there protections so that children are not just “warehoused”?

Australia – post-graduate early childhood researcher

It will be an overwhelming experience for young children to be in such a large facility. Even children in prep are not placed with so many other children in one classroom.

UK – early childhood educator

Increasing to these numbers will have the potential for quality of care to drop and children to lose their individuality in settings.

Australia – Researcher and early childhood consultant

Stress levels will rise….especially cortisol levels (See Simms research studies). Children find it more difficult to concentrate on people and experiences when there are too many people in the room and too much ‘normal’ noise. I have also used video footage in the US of babies with 2 staff and in a group of six showing distress and physically clinging onto any staff they could find. And then they put a low divider in the room…the babies behaviour was dramatically different even though there were still only 1 staff for 3 babies. Staff could see each other, but not the babies.

I would urge every centre to invite a politician to visit centres and show them what it would be like if the groups were larger. 

Also I think the fire brigade etc would argue against the bigger groups for evacuation reasons and the medical profession for health reasons.

Singapore – early childhood manager/teacher

I think there is nothing to be alarmed by this increase in nos of children licensee can have. Rather the emphasis should be on maintaining good quality trained staff, good environment, sufficient teaching resources, good working relationship with parents and the community

Canada – early childhood manager and consultant

Some of your best centres will be larger than 50 and in time you will see some of the benefits of larger organizations, at least that is what happened in our province of Canada about 10 years ago. Child staff ratios did not change and we still have a maximum group size of 16 children at the 2-5 year old level so things did not change much for children, but our administrative organisations did change.  In our province the group size can not exceed twice the child-staff ratio. Since our ration is 1-8 for kids 2-5 years that means no more than 16 kids in a group

Your system will probably change and be more compatible with the Primary Education system.

Your system will likely be more vulnerable to commercial child care interests.

Australia – teacher educator/academic

Your maximum group size is too large to deliver responsive caregiving with infants.

What health professionals, child advocates and school teachers had to say

Also for readers of this report, we have included a sample of the range of responses received from professionals working in a health or educational capacity in the wider community. From the perspectives of people involved in child health, advocacy, family support and parenting education the regulation change to increase centre licence change is considered to be wrong and likely to have quite serious consequences for children and other costs to society.

Child and Family Advocate

Grizzly and unhappy children because of feeling less secure. Increase in stress disorders in parents who will worry about the well being of their child and more possibility of child abuse occurring as a result. This is such poor short term thinking and will have serious impact on the mental well being of children and parents. We all need to speak up and STOP this today.

Primary School Yr 1 & 2 Teacher

There would be less time for them to have rich learning experiences with teachers. It will be loud and there may be excessive stress put on the children if a few are upset. The learning experiences may be stretched to accommodate so many children. The care of that many young ones may cause educators to miss important signs from the children of distress.

Plunket Nurse

The importance of one to one care, ideally a parent, cannot be understated. There is a need for childcare, and it is vital to ensure it is not only available but of the highest standard possible.  

Primary School Teacher

Small class numbers are much better. Less positive interaction with more children.

National Parenting Programme Educator

Young children need individual attention and care and build close relationships with carers and can only socialise in small groups.

Breastfeeding counsellor

More likely greater numbers of carers will result in less good attachment for infants to one main carer. Too many peers of the same age in one setting and less mixing with other age groups will mean limited learning from older child role models. Higher risk of spread of disease. Less attention to the needs of breastfeeding mothers and breastfed infants using the service.

Plunket Nurse

NZ Children’s health already is already below WHO standards. Attachment is important to shape a secure child and adult. I do not see how a child’s needs would be met if numbers of children in centres increased.


When has it ever been ‘normal’ to have that number of children being cared for in one house/childhood service at any given time?

Registered Nurse – Hospital

Care will be affected and health outcomes compromised if this is allowed to go ahead. Increased infections, i.e. ear, nose throat and respiratory diseases.

Parenting Advisor

Evidence based research and what is best for all children should drive this, not a desire to see all children in ECE and all parents in the workforce!

Infant & Child Advocate

Quality in ECE will be seriously compromised and this is not in the best interests of children – probably health and safety too.  It will be harder to regulate quality and the effects on staff will also cause issues.

Plunket Nurse

Increased numbers of children in close contact will contribute to increased spread of bacteria and viruses. Less individualised attention for the children, noisier environment creates poorer learning and increasing distraction for children and teachers.

Child Advocate with International Organisation

Worldwide studies verify that smaller numbers, particularly for under 2’s are essential for adequate attention and to lessen stress on children and staff. The impact on children will be high level of stress through interaction in large group and potential for less attention to individual needs.

Health Professional Working with Children with Disabilities

Services will unlikely be able to provide individualised high quality care and education, particularly to children who require early intervention.

Health Worker

Potentially too many children in one place – not so good for children as I see it. Lots of things about them may go unnoticed. Less one on one care and a higher chance of illness.

Child Health Services Manager

Crowding in any environment is not conducive to managing illness and transmission of disease. Children fall ill often in their first year at childcare as they are exposed to a wider range of viruses and bacteria than in their home environment. As we welcome increasing numbers of migrant families into our communities, infections such as TB are being seen more in our communities.  Many parents would prefer to have their children at a smaller centre, but economies of scale may make the smaller centres affordable for wealthy families only. This means the large cheaper centres with increased risk of infection will be more accessible to vulnerable lower income families.

Health Practitioner and Spiritual Healer

Children were born to be in small family groups (not herds) and will grow the best with one-on-one interaction initially expanding into smaller group dynamics once they feel safe to involve with others. A baby’s needs are one-on-one to develop and know that their needs will be met. This in turn develops trust and a sense of well-being.

Anger and language

Perhaps it should be mentioned here that the issue of increasing licence size was one that elicited some strong and emotional responses. Some phrases popped up fairly frequently across completed survey forms – comparing “packing ‘em in” in with baby-farming, battery hen farming practices, orphanages, and treating children as cattle or sheep to be ‘herded’. For example:

It will become like a stock yard of cattle no quality, no care, no education

Two words – Baby Farm

75 babies – Romanian Orphanages

Children need not be battery farmed!

Reminds me of cattle farming.




This is inhuman

The children are used as a commodity

No children are not sheep in a yard.

Teachers will once again be viewed as nothing more than glorified babysitters.

How on earth can we provide quality early childhood education in orphanage type institutions. 50 plus children are institutions nothing more.

This suggests that perceptions of the quality of early childhood education will be negatively effected if the licence number is increased and if it is increased without restrictions on group size within the licence number.   

The Benefits for Children

The survey asked respondents the following open question:  “What impact will an increase in licence size likely have on children?”  A content analysis of the responses received found that few respondents mentioned positive impacts for children. It could be concluded therefore that the change in regulation is generally perceived to be for purposes other than the benefit of children. 

Thirty-Eight of the 450 respondents wrote positively about the regulation change in reply to this question:

  • It would be positive for children at their centre (3 respondents),
  • It would be better for children or at least no problem for children at any centre with a larger licence size (10 respondents)
  • There would be no change for children when a centre moved from having multiple licences to a single licence (8 respondents)
  • Providing other standards remained in place and/or maximum group sizes were  introduced there would unlikely be an impact on children (17 respondents)

a) Positive for children at their centre, e.g.

Hopefully positive – there is less administration in running a centre with one licence centre versus multi-licences so we will have more time for children and more money for resources.

In my case, I would hope none except to make it easier for me to move children between play areas (rooms) when developmentally ready rather than by age.

b)  Better for children, or no problem, at bigger centres, e.g.

All existing big centres are well spaced and have quite good play areas.

I think the children will do fine. Centres and teachers have the interests of the children in mind – and they don’t get bums on seats unless they provide a good service.

c)  Nothing would change for children in centres that went for multi-licence to single licence, e.g.

At our service there will be no change in terms of how we care and educate the children. We are very aware of optimum group size and our building spaces are designed to hold comfortably 25 under 2’s and 40 – 45 over 2s.

In our instance the impact will not likely be noticed by the children, except for the fact we will not have to have a fence now in between the playgrounds to separate the groups of children. 

d)  Providing other standards remained in place and/or maximum group sizes were introduced there would unlikely be an impact on children e.g.

It may not have an impact if group size is addressed.

Should have none if teacher quality and ratios remain the same and there is sufficient space and other resources to ensure the high quality presently delivered.

It will depend on the owners.  It could be dangerous if they don’t understand quality practices and consider within the overall licence reasonable group sizing and good development of learning environments. 

Risks for Children

Considerable concern was expressed about potential negative consequences for children of the regulation chane.

An increase in licence size was likely to affect children badly for a variety of reasons. These reasons were what respondents thought of first to write when replying to the open question of “what impact will an increase in licence size likely have on children?”:

  • Recruitment and retention of qualified staff which will in turn affect children (11 respondents); and staff stress, turnover, and health (43 respondents),
  • Children getting ‘lost in the crowd’ and missing out on personal care and recognition of individual needs (152 respondents),
  • Less interaction, a lower quantity of interaction, and competition for adult time (33 respondents),
  • The quality of interactions – relationships being harder to maintain (102 respondents),
  • Children’s psychological wellbeing, ability to form attachments with caregivers/educators, to enjoy responsive relationships and intimacy (133 respondents),
  • Children’s behaviour and aggression (25 respondents),
  • Higher noise levels (72 respondents),
  • Risk to physical health and safety (56 respondents),
  • Children’s learning, engagement with the curriculum, and the quality of assessment and programme planning (93 respondents),
  • Access to space, personal space, equipment and resources (32 respondents), and
  • Loss of family involvement, belonging, and ‘bigger services everywhere (25 respondents).

a) The survey did not include a question on what the impact on staff would be, but some respondents made the point that it could mean lower quality staff, difficulty recruiting and holding onto qualified staff, and that stress levels for staff would be high, which in turn would impact negatively on children’s care and leaning. For example:

As it is the staff turnover in some of the larger centres is too high already. The larger the centre, the higher the stress levels and the more likely the regulation change would be to impact on staff turnover.

There will not be enough registered teachers for different services.

More unqualified teachers will be used as much as possible (less expense).

Staff will be untrained so will not be able to offer quality learning experiences.

I have worked with 24 under 2’s and that group size was pushing the boundaries of stress for the staff and children, as well as levels of quality. Even though the size of the physical environment would allow for another 20+ I couldn’t see how this would work, or how the centre would keep its staff.

Staff could easily feel overwhelmed and feel they are not making a difference – they would feel they were caught in a factory model of early childhood education.

They [children] will be in groups with a high number of children and adults and higher noise levels. This alone is stressful for adults … Also it will be very hard for the adults to give children the time and energy they need.

It will negatively effect both adults’ and children’s health, development and well-being.

b)  By far the greatest number of respondents commented that children would be less likely to receive personal care and attention, and their individual needs might not be well known or met by teachers. Here is a sample of the comments about this:

Individual needs will be put even more behind programme structure and routine to keep the childcare business running.

Children will become known as a number.

I have known many parents who have left larger centres because they didn’t know who was looking after their child from one day to the next.

Large numbers will mean that the children who are generally quiet may get lost in the crowd.

Less ability for teachers to pick up any developmental issues or individual direction required for a particular child.

It will lead to degradation in care of the children as the service focuses on numbers and not on the needs of the individual children.  It will also reduce the service’s ability to respond flexibly to children.

No opportunity for individual attention; getting to know the child and able to respond to a child’s interests and needs.  Rushed routines rather than caring and responsive routines.

Even if adult-child ratios remain the same – the sheer volume of children would make for “crowd control” rather than care and education.

Educators will not have time and space to get to know children as deeply as they do within smaller groups.

I have previously worked in a centre with under 2s. Children need more 1 on 1 time at this age level. By raising the numbers it will cause some children to be neglected. 

c)  In addition some respondents mentioned children would likely experience less talk with adults, for example:

Less interaction with adults/teachers, more competition for teacher’s time.

Even fewer joint attention sequences (two-way conversations) for infants and toddlers.

Interactions are less likely to be of regular occurrence for every child.

d) Being in environments with more children and adults could result in children being less likely to form attachments and friendships which could have consequences for emotional development. Comments about this show a lot of concern, for example:

Children need to have an ‘attachment’ with a carer, to give them a sense of security to enable them to thrive, grow and learn. The change in regulation will dilute the relationship children have with carers as the rolls grow to an enormous size. This in turn will leave children feeling vulnerable and unsafe/insecure.

Less bonding between a child and their carer which will lead to separation anxiety and children having lower confidence levels.

Lots of people will come in and out of children’s lives and this will be very unsettling and have a great impact on their ability to form relationships.

I believe children will experience centres as institutions rather than cared for as part of a centre whanau. The ramifications of this are far reaching not only for individual children but society in the future.

Insecure attachments or none at all. Mental and emotional health issues growing in society because early brain development will likely be impacted.

Many poor relationships rather than few warm and secure relationships – particularly for Under 2s.

I do  believe this will (and my experience has shown) that this will cause the child to withdraw and then eventually be unable to develop in a healthy way.

e)  The impact of the regulation change on children’s behaviour was highlighted by respondents,  for example:

Without the extra attention … many may act out, creating danger for other children around them.

More opportunity for bullying to go unnoticed.

More conflicts between children

I can  imagine more disputes, louder voices so the children can be heard, and more chaos being created.

Behaviour management policies will not be able to be enforced properly if there are 150 children in the centre as the teachers will have different approaches and it would be hard to keep everyone on the same technique, so the children will end up feeling confused and their behaviour will change as they do not have the consistency they need.

It will increase the fight or flight mentality, it will increase aggressive behaviour and increase competition. It will not create settled, well balanced, happy children.

f) A number of respondents mentioned higher noise levels as something that would not be good for children, for example: 

Noise is a huge issue.  Large centres have high noise levels and increase stress in children.

Children and adults alike could suffer from the impact of increased noise levels.

Could have negative impact on some children who learn best in a quieter environment.

The noise level will be a health and safety issue, and it will not be an environment that is conducive to educating young children.

Many children with identifiable needs such as those on the autistic spectrum, hearing impaired and those with speech communication, auditory and intellectual impairment struggle, and this regulation change will only compound the problems that they already have. I think it is cruel to subject these children to excessively noisy and stimulating environments.  By relaxing the regulation over maximum numbers, these larger centres may not be able to meet the requirements of Regulation 46 (Education, Early Childhood Services Regulations 2008) and the Licensing Criteria especially HS15.

g)  Some respondents made general comments relating to increased risks for children’s health and safety, including increased exposure to infectious diseases, for example:

Children will be more exposed to illness, and the likelihood of cross-infection.

It is likely that there will be health issues, more ear infections, colds and other diseases spread around.

Prone to more accidents.

Has anyone considered the impact on the outdoor spaces for children? Will this mean one large outdoor space?  150 preschool aged children (including 2 year olds) in one large outdoor space?? I would be concerned for children’s safety.

Should there be an emergency, how would we evacuate all children safely, and to where?

h)  It was believed that larger centre size could have a negative impact on children’s learning, on their engagement with the curriculum, and on assessment and teachers’ planning. For example:   

Small group learning is better for small children – the smaller the child, the smaller the group needs to be.  

Would we do this to adults in education – put them in a class with 150 others and expect quality learning or collaborative learning?

Large ‘class size’ will lead to less child centred learning and an introduction of, or an increase in, teacher directed ‘force feeding’ which is an unnatural style of ‘education’ for young children.

Profiles and individual planning would be reduced.

Teachers not knowing the child and not enabling them to plan effectively.

i)  Access to space, personal space, equipment and resources were mentioned as things that could negatively impact on children’s well-being and learning. For example:

Space and freedom are things I do not see possible.

Children need space for free play.

Ability to find quiet spaces would decrease

Children need space to develop their walking and running skills.

Impact on spaces available for children and resources to meet their needs.

j)  Loss of family involvement, loss of a sense of ‘belonging’ and ‘bigger services’ was  mentioned specifically by a small number of respondents as having a potential negative impact on children.  For example:

Stressed and rushed teachers not able to get to know families and respond to their needs.

Lack of access to quality Samoan language from the teachers (small ratio) OR any Pacific ECE service in the country.

Staff will lose the good contact with families/whanau if such a large no of children are being cared for.

Relationships will be estranged, quality versus quantity and having the right people in place to ensure that the centre’s philosophy is paramount, especially for a centre similar to mine which actively promotes Maori values and beliefs with te reo in mainstream education. Our identity and ways of doing things could be lost. 

Impact on Services 

In reply to the open question of: “what impact might this change in regulation possibly have on the availability of smaller and locally operated early childhood services on families?” there was little divergence in answers given.

Most respondents thought the regulation change would be good for companies and organisations that went big – but also bad for those services that held on to their current licence size and did not expand.

Why?  Here are some reasons why respondents thought this:

If you compare it to retail businesses, look at the impact mega stores and malls have had on local shopping malls.

Smaller services will find they can no longer compete with the ‘multi-national’ type of centres. The bigger services will have the monopoly and will have the ear of Government. I suggest it will be very difficult for community based programmes to get the funding they need. They will be edged out by the smart (so called) operators.

Franchises may take over and push them out.

Financial imperatives in these difficult economic times will force services to move to the larger models.

The cost per child will go down with larger centres, bulk buying power etc etc. The smaller centres will have higher costs and will be less flexible in hours in order to ensure a steady income stream, and will eventually close.

The large centres will be able to afford to charge lower fees, thus encouraging parents in these financially strained times to use them.

Larger early childhood services will have the finances to convince families (customers) that their children will be better off in a larger centre. 

Who will this disadvantage?  It is likely to disadvantage families who want early childhood education to be provided close to home or within their neighbourhood and not within industrial or business areas. It will disadvantage lower-income families. It may mean less choice of services with different philosophies and providing for different cultural or other needs. It may become harder for families to get access to a place in a service of their choosing. For example:

If one centre in our area decided to expand it could well put into doubt the viability of both our services and the local crèche.

The cost impact it will have on smaller providers. Larger conglomerates taking over. A  lack of facilities [for different cultures] e.g. Kohanga Reo.

I imagine there will always be families who choose quality for their children.  However, in poorer areas it may, from necessity, be cost that decides – not a happy choice for parents. 

Economies of scale may make the smaller centres affordable for wealthy families only. This means the large cheaper centres with increased risk of infection will be more accessible to vulnerable and lower income families.

It will once again make it more difficult for communities to establish and maintain not-for-profit centres in their local areas.  Profit will drive education for our children.

Smaller services will be more niche market priced and costly and will have increased waiting lists – as is already the case.  My granddaughter has been on a waiting list for a great programme since being born and is not likely to secure a place until about 20 months old. 

Some respondents viewed the regulation change as being something that could be positive for smaller and locally owned services They could see a silver lining which was the creation of a clear and strong point of difference between early childhood education services based on child numbers.  This point of difference could go in favour of smaller services being presented with an opportunity to articulate their specialness and be highly sought after.   For example:

May actually have a positive impact, meaning a more loyal clientele who favour a more ‘personal’ environment for their child.

Possibly will increase participation in smaller centres  parents realise what ‘factory preschools’ offer.

I would hope that if services market their service well, small intimate, professional, “we know your child” then maybe it would benefit the service”. Somehow the message must get through to parents that big is not good for infants, toddlers and young children.

There will always be a need for these. Many parents would prefer the smaller more intimate services. It will be very difficult to give a 75 licence that intimate, homely feel.  Another thought is who would afford to build them, the car park would be a nightmare, fire and earthquake drills oh my god, staff rooms, kitchens laundries – I have a headache. A baby factory of this size would never out destroy the smaller centres.

We will be promoting our smaller centres as the optimal learning environments that they are … creating a family like environment where we all know each other very well, where we all have a shared sense of belonging, not just one in a number!

The regulation change may negatively impact on the reputation of all teacher-led centres as parents knowing that numbers can be large, might be more likely to decide without looking around at centres first, not to use an early childhood centre. For example:

More parents will choose home based care options so that they can guarantee consistent and safe caregiving for their children.

Under 2’s spaces are currently at a premium, however, how would parents feel about leaving their very young child in such a large group size?

Even more grandparents will take on the caring role, especially for under-2s because parents can’t afford/don’t want institutional care. 

Support for Group Size Regulation

Most respondents (81%) supported the idea of new licensing rules for group size within early childhood centres, as a way to mandate for smaller group sizes.

Absolutely. Detrimental impacts on children’s social learning and emotional regulation otherwise.

It is important to have restrictions on the number of children who are being cared for in one centre. Without this the care becomes impersonal.

Group size has been shown to be an important indicator of quality for the care of young children – I think that even 20 is maybe too many!

Provided they are in different indoor rooms that can cater to a group of 20. That is, say four different kindergartens within one kindergarten.

I think this is really important and needs to be addressed with urgency

Of the 19% who replied ‘no’ or were undecided if they supported the introduction of rules to limit group size, most said this was probably unnecessary as their service already practiced having smaller group sizes within the licence size, or other indicators of quality were important also such as ratios.

Not necessarily for pre-schoolers, 3 to 5 years, if ratios are adequate and the programme and environment supports this

Yes in principle but not in practice. Trying to re-design existing centres would not be economic.

My response to this would depend on what the regulatory framework was around ratios and minimum space requirements.

The actual group make up and environment add greatly to quality care not just group number in isolation

And, some thought that it should be up to individual centres whether and how to group children, or that the cost of implementation should be considered. For example:

As long as these rules are not based on one qualified person for 4 babies. We need not have a  qualified person looking after babies and drive the cost of care.

External, inflexible rules should not replace independence of onsite management.


Maybe there is not a need for a change in the regulations for licence size? Perhaps the problem of paperwork and bureaucracy stemming from large services having more than one licence per each group of 50 children, could be addressed in another way?  Then group sizes at a maximum of 50 in each centre space within a service for pre-schoolers or 25 for under 2s could be retained, or until such time as regulations are developed for group size and conditions are developed to help to mitigate against the potential risks for children of larger scale ECE provision. 

Most of the current ‘large’ providers and chains of early childhood services who responded to this survey were generally supportive of having class sizes smaller than the licensing size. They may not have a problem with maintaining current licence sizes (or less) as the new ‘group sizes’, providing compliance costs can be better managed.

However, there is still the issue of whether increasing the total number of children in a centre facility is a good thing for children (and for staff). This does seem to merit more research and more discussion, especially as once the regulation change comes into effect it may be difficult to go back to having centres with smaller child numbers.

The results of this survey show substantial opposition to increasing the licence size. It appears that Government hasn’t communicated this policy change well or convincingly.    

How might government get better buy-in and reduce criticism (especially as this is election year!)?  Government could respond positively by seeing this as an opportunity to show it listens and recognises that the regulation change shouldn’t be rushed through. Perhaps the Minister for Education and/or Government might consider:

  1. Postponing implementation, allowing time for discussion and open debate as part of the democratic process.
  2. Asking officials to investigate what the consequences are likely to be for all groups affected by the regulation change and to undertake a cost-benefit analysis.
  3. Asking the Education Review Office to look into and also provide any data they may already have on differences in quality for children’s learning and care between centres that vary in licence size and between centres that have multiple licences for more than 50 children on the same site or have a single licence.
  4. Talking with the Commissioner for Children who has completed an inquiry into infants and toddlers in ECE about optimal group sizes and other recommendations for improving ECE standards, parental choice and decision-making. The Commissioner’s recommendations need to be taken seriously and used to inform policy development.
  5. Asking officials to research and put forward a proposal for what conditions should be placed on services that increase their licence size beyond the present maximum (ideas proposed by respondents in this survey for example included: introducing maximum group sizes within the licence size, ensuring that groups have separate spaces, and reducing teacher-child ratios particularly for under 2s). 

There may be practical solutions to the problems raised in the survey feedback which would allow for the regulation amendment to be less risky for children’s care and education. Here are some ideas

  • Maybe the Ministry could help to support the establishment of regional networks for locally owned and community small early childhood services so they can combine their purchasing power for resources and save on costs, such as for advertising for staff?
  • Possibly ECE funding could go to parents instead of services, supporting parental choice and decision-making, as suggested in the recently released report on the child care of Under 2s by the Children’s Commissioner? 
  • Perhaps the owners and directors and managers of the biggest ECE teacher-led centre services could plan together how they might show the rest of the sector and the public a unified commitment to providing services that are of high quality for individual children?
  • Possibly an advertising campaign is needed to let parents know about the features of an early childhood service that are typically linked to better learning, social, and psychological outcomes in young children?
  • Maybe the new centre licensing fee charge could be linked to the number of children, so then the fee amount paid by services reflects the number of children they are licensed for rather than smaller services paying proportionately more?

Has this been useful?  Give us your feedback.

You are welcome to add a link to this page on your website. Copyright belongs to the OECE so please do not copy any content without our written permission.

Information provided is of a general nature. It is provided ‘as is’, and we accept no liability for its accuracy or completeness. See our Terms and Conditions.

Related Posts

Child looking at night sky for Matariki.

Matariki – July 14, 2023

Matariki in Early Childhood Education. This article presents ideas and teaching and learning activities for marking this culturally important event in the curriculum of early childhood education centres and home-based services.  In late May or early June, a cluster of seven […]

To access this member only information, you must purchase Teacher Membership.

Read More »
what to put in child's lunch-box

Lunch-Box Tips

Lunch-box tips – share the link to this article with children’s parents and caregivers. Type of Lunch-box Recycled ice-cream containers with a lid can make

Read More »
earthquake early childhood centre

Earthquake Drills

Earthquake Drills and the Turtle Drop – Reflections and Discussion about what is Best Practice. By Warwick Marshall  A big earthquake shakes while you’re in the kitchen at your house.  What do you do?  Of course you throw yourself to […]

To access this member only information, you must purchase Teacher Membership.

Read More »
The Office of ECE

Share This Information

Table of Contents

Table of Contents

The Office of ECE Login

Take Action!

Help spread this vital ECE information, join our free social and email groups and become a member of OECE.

pay parity funding policy

1. Share This Information

2. Follow Our Social Pages

3. Get Regular Updates

Sign up to our free newsletters.

4. Become a Member

Public Area Categories