The Waipounamu Erosion Surface is a time-transgressive, nearly planar, wave-cut surface. It is not a peneplain. Formation of the Waipounamu Erosion Surface began in Late Cretaceous time following break-up of Gondwanaland, and continued until earliest Miocene time, during a 60 million year period of widespread tectonic quiescence, thermal subsidence and marine transgression. Sedimentary facies and geomorphological evidence suggest that the erosion surface may have eventually covered the New Zealand subcontinent (Zealandia). We can find no geological evidence to indicate that land areas were continuously present throughout the middle Cenozoic. Important implications of this conclusion are: (1) the New Zealand subcontinent was largely, or entirely, submerged and (2) New Zealand's present terrestrial fauna and flora evolved largely from fortuitous arrivals during the past 22 million years. Thus the modern terrestrial biota may not be descended from archaic ancestors residing on Zealandia when it broke away from Gondwanaland in the Cretaceous, since the terrestrial biota would have been extinguished if this landmass was submerged in Oligocene–Early Miocene time. We conclude that there is insufficient geological basis for assuming that land was continuously present in the New Zealand region through Oligocene to Early Miocene time, and we therefore contemplate the alternative possibility, complete submergence of Zealandia.