Parole Board member Justice Marion Frater said Mikus had consistently failed to engage with the parole process "from the beginning".
"Nor has he taken any steps to address his very serious sexual and violent offending. He has declined to participate in assessments for the Parole Board and declined to participate in any interventions with a departmental psychologist," she said in the decision released yesterday.
"Given his assessed very high risk of sexual re-offending we are satisfied that even if MrMikus changes his mind and engages now, it will take at least five years before there is any prospect that he could safely be released.
"Accordingly, we make a postponement order of the maximum duration of five years from 16 December 2015, when parole was last considered.
"This means that Mr Mikus' next parole hearing will be scheduled on a date between October and December 2020, but in any event before 16 December 2020," Justice Frater said
Before that time, if Mikus believes there has been a "significant change in his circumstances" he can apply under s27(6) of the Parole Act 2002 for an earlier hearing.
Teresa lived in Napier at the time of her death with her mother Kelly Piggot and younger sister.
She was kidnapped by Mikus while walking to school. Eight days later the little girl's body was found under a tree on Whirinaki Beach.
A post-mortem examination revealed she had been raped and then suffocated.
Mikus, a transient, had lived in Masterton off and on over many years and was living in the town at about the time Teresa was abducted and killed.
He lived in Kummer Cres but court records of the time, not linked to the Cormack murder, show a home address in that year to be the Salvation Army hostel in Lincoln Rd and also a Napier address.