The Parole Board says the man who abducted, raped and murdered Napier girl Teresa Cormack is effectively resisting any attempt to get treatment.
An official report says Jules Mikus did not attend his first parole hearing in February this year and still adamantly denies killing the six-year old in 1987.
A Parole Board decision says Mikus is still considered a very high reoffending risk and is expected to undergo a programme for child sex offenders in 2013.
However, the board says his continued denial of guilt represents a considerable impasse and is likely to be a block to any treatment.
The board says it is not sensible to continue seeing Mikus yearly if nothing is changing and it will consider deferring his eligibility to be considered for parole every year.
Mikus rejected a request by Radio New Zealand to attend the hearing but, in a letter, says some evidence in his defence has not yet been heard and he is working to get the case re-opened.
Kelly Pigott, the mother of Teresa Cormack, says she does not see how rehabilitation is possible for Jules Mikus, but it is time that he faced up to his actions.
"The lack of remorse ... seems very cold-hearted to me. How can you rehabilitate someone who can't even accept the truth about themselves?"
Keith Price, a former detective sergeant who dealt with Mikus, believe he will never admit to the crime and there is no point sending him on a course for something he does not think he has done.
"He should just never get out. I did 28 years in the police and worked on quite a few homicides and interviewed quite a few offenders.
"He would be the coldest, hardest person I've ever come across. Just the denial and the cold look he'd give you, (but) the evidence is pretty overwhelming, very overwhelming."