The Otago Regional Council is not likely meet the standards of a Government investigation, as the Environment Ministry has different ''goalposts'' for critical water work.
The review, launched by Environment Minister David Parker, will begin this month.
It will assess whether the council is prepared to meet deadlines for plan changes and deemed permit expiries in the Arrow, Cardrona and Manuherikia catchments.
At a recent council meeting, chief executive Sarah Gardner said the minister had different ''goalposts'' for what needed to be completed by deemed permit expiry.
The council was working towards plan change notification by the 2021 deadline.
The minister confirmed this week his expectations were for decisions to be notified and all subsequent appeals resolved by the same time.
The council has said it is unlikely to meet this target.
Council policy, science and strategy general manager Andrew Newman said it was confident in the timeline it set and would ''continue discussions with the ministry'' as it progressed.
If the plan was appealed to the Environment Court, then it still had legal effect, but was not fully operative, he said.
Its timeline meant deemed permits could be replaced in line with the notified plan, ahead of their expiry date in October, 2021.
Mr Parker said his concern was ''if appeals on a minimum flow plan change remain unresolved at October 1, 2021, there will still be no certainty for permit holders and others with an interest in the water''.
He wanted to do what he could to assist the council's work.
If the council did not meet the deadline, he had various powers to act on, but he reiterated he did not intend to appoint a commissioner.
Chairman Stephen Woodhead said getting to notification, particularly for the Manuherikia, would be a ''challenge''.
However, he noted the minister also said if a single regional plan to implement national direction could not be completed in time, a narrower plan change would be necessary to respond to those matters.
''We agree with the minister on that point.''