Well I suppose under the convoluted 21st bureaucratic language they might meet that definition.
But this means they have to register with the Government and become licensed. And this of course requires meeting all the regulations pertaining to "early childhood development units" covered by statute. Whatever they are now and whatever they may become in the future.
How long before some bright spark secularist requires equal time for "other religions" alongside Christianity in a Church Sunday school? After teaching children of Christ's ascension into Heaven it will be mandated that a similar event from Mohamed's, his convenient ascension from Temple Mount in Jerusalem be given equal time.
Perhaps safe sex indoctrination may become a requirement in the near future. Because this would directly contradict the teaching of many Churches it would probably see the end of Sunday Schools and Catechism classes in those churches.
And that may well be the endgame.
Further reading: Family Party Opposes Sunday School Licensing
National Party Statement from Paula Bennett as highlighted by John Boy in a comment