The Parole Board has invoked its harshest penalty, a three-year parole freeze, for the man who raped and murdered Napier six-year old Teresa Cormack in 1987.
Jules Mikus, 53, is serving life imprisonment and preventive detention for the crime, which he continues to deny.
Mikus first became eligible for parole in February.
He is still considered a very high risk of reoffender, and is scheduled to attend the child sex offender programme next year.
But the Parole Board says there is no certainty Mikus will even get on the course because he denies the offending.
Mikus refused to attend a hearing last week to postpone his annual parole eligibility and his lawyer did not make any submissions.
It will be 2015 before Mikus can next seek release.