Mandatory climate-related disclosures

2025 Capital Markets Reforms

In October 2025 Cabinet agreed to adjustments to the climate-related disclosures regime as part of a broader suite of changes to reinvigorate New Zealand’s capital markets.

The adjustments will:

• remove managed investment scheme managers from the regime so that they are no longer required to report;
• raise the listed issuer reporting threshold, in relation to both market capitalisation (equity issuers) and face value of debt (debt issuers) from $60 million to $1 billion;
• adjust the liability settings so that directors do not have deemed liability for entity breaches and climate reporting entities and their directors are not liable for unsubstantiated representations in their climate statements – if they comply with the climate standards;
• enable the monetary reporting thresholds for the regime to be raised (but not lowered) by Order in Council, with appropriate safeguards.

Next steps

It is intended that legislation to put these changes into effect will be passed in 2026.

Purpose of mandatory reporting

The goal of mandatory climate-related disclosures is to:

• ensure that the effects of climate change are routinely considered in business, investment, lending and insurance underwriting decisions;
• help climate reporting entities better demonstrate responsibility and foresight in their consideration of climate issues; and
• lead to more efficient allocation of capital, and help smooth the transition to a more sustainable, low emissions economy.

Legislation for mandatory climate-related disclosures

Part 7A of the Financial Markets Conduct Act 2013 requires large financial market participants to make climate-related disclosures in annual climate statements. Disclosures are publicly available on the Companies Office Climate-related Disclosures Register.

Climate-related Disclosures Register(external link) — New Zealand Companies Office

Financial Markets Conduct Act 2013(external link) — New Zealand Legislation

Compliance with the mandatory reporting requirements

Organisations that must make disclosures

Around 170 financial market participants in New Zealand are required to produce climate-related disclosures. Climate reporting entities include:

• Registered banks, credit unions, and building societies with total assets of more than $1 billion. 
• Managers of registered investment schemes (other than restricted schemes) with greater than $1 billion in total assets under management.
• Licensed insurers with greater than $1 billion in total assets or annual gross premium revenue greater than $250 million.
• Large listed issuers of quoted equity securities or quoted debt securities. An equity issuer is large if the market price of all of its equity securities exceeds $60 million and a debt issuer is large if the face value of its quoted debt exceeds $60 million. Issuers listed on growth markets are excluded from the climate reporting entity definition.     

Overseas incorporated organisations will be required to make disclosures if their New Zealand business is over the thresholds outlined above.

These reporting thresholds will be impacted by the reforms agreed by Cabinet in October 2025.

Capital Markets Reforms

Reporting standards

Climate reporting entities report against standards issued by the External Reporting Board (XRB).

Aotearoa New Zealand Climate Standards(external link)  — External Reporting Board

The standards were developed largely in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). The TCFD recommendations are a leading framework for climate-related disclosures internationally. The recommendations are structured around 4 thematic areas that represent core elements of how organisations operate: 

• governance
• strategy
• risk management
• metrics and targets.

Final Report: Recommendations of the Task Force on Climate-related Financial Disclosures(external link)  — TCFD

The XRB has consulted about the international alignment of New Zealand’s climate standards:

International alignment consultation(external link) — External Reporting Board

Regulations to support the climate-related disclosures regime

The Financial Markets Conduct Regulations 2014, Financial Markets Conduct (Fees) Regulations 2014 and the Financial Markets Authorities (Levies) Regulations 2012, provide for:

• the manner in which climate records need to be kept and made available for inspection;
• fees for filing and infringement fees for non-compliance with record keeping obligations;
• technical requirements relating to the functioning of the Climate-related Disclosures Register;
• the payment of levies by climate reporting entities.

Financial Markets Conduct Regulations 2014(external link) — New Zealand Legislation

Financial Markets Authority (Levies) Regulations 2012(external link)  — New Zealand Legislation

Financial Markets Conduct (Fees) Regulations 2014(external link) — New Zealand Legislation

Assurance Requirements

Assurance over greenhouse gas emissions

Climate reporting entities must ensure that the parts of their climate statements relating to greenhouse gas emissions are independently assured. An assurance report must be lodged with the climate statement.

Refer to the XRB website for information about relevant adoption provisions:

Adoption of Aotearoa New Zealand Climate Standards(external link) — External Reporting Board

Monitoring, supervision and enforcement of the regime

The Financial Markets Authority (FMA) is responsible for the independent monitoring, supervision and enforcement of the climate-related disclosures regime. The FMA have committed to taking a constructive and educative role in the early stages of implementation. The FMA have published guidance around their oversight approach for the first three years of the regime, as well as other guidance materials for climate reporting entities on their record-keeping obligations, and information on exemptions, which can be found at the below link.

Climate Reporting Entities(external link) — Financial Markets Authority

Previous consultations

Strengthening New Zealand’s capital markets

MBIE consulted on proposals to strengthen New Zealand’s capital markets, including adjustments to the climate-related disclosures regime, from 13 December 2024 to 14 February 2025:

Capital Markets Reforms

MBIE received 93 submissions on changes to climate-related disclosures from a wide variety of submitters including climate-reporting entities, peak bodies, individuals, not-for-profit organisations, academics, law firms and consultants. Submitters expressed varying views on the regime. Some key themes were that compliance costs were high, managed investment scheme disclosures were not fit for purpose, and liability settings were too strict and discouraging meaningful reporting.

Read the submissions:

Climate-related disclosures submissions

Enabling KiwiSaver investment in private assets submissions

Assurance over climate-related disclosures

MBIE and the Ministry for Environment (MfE) publicly consulted on the future of assurance obligations for climate reporting entities.

This consultation closed on 10 February 2023. No legislative changes were made following consultation.

Development of the legislation

Development of the Bill

In October 2019, MBIE and MfE released for public comment, a discussion document setting out the rationale and initial proposals for the regime. Feedback from the consultation informed the Cabinet paper submitted in August 2020, seeking approval to introduce mandatory climate-related disclosures in New Zealand.

• Climate-related financial disclosures discussion document(external link) — Ministry for the Environment website
• Climate-related financial disclosures: summary of submissions(external link) — Ministry for the Environment
• Cabinet paper: Climate-related financial disclosures(external link) — Ministry for the Environment
• Regulatory impact assessment: Climate-related financial disclosures(external link) — Ministry for the Environment
• Low emissions economy report(external link) — New Zealand Productivity Commission

In April 2021, Cabinet approved for introduction the Financial Sector (Climate-related Disclosures and Other Matters) Amendment Bill.

Development of the Regulations

To ensure that the regime operates as intended, Cabinet agreed to introduce regulations to support the regime.