Mandatory climate-related disclosures
The Government has introduced legislation to make climate-related disclosures mandatory for some organisations. The requirement would apply to publicly listed companies and large insurers, banks, non-bank deposit takers and investment managers.
The mandatory regime would be introduced through an amendment to the Financial Markets Conduct Act (2013). If approved by Parliament, the legislation will require around 200 large FMC-reporting entities to start making climate-related disclosures for financial years commencing in 2022, with disclosures being made in 2023 at the earliest.
Purpose of mandatory reporting
The majority of large New Zealand entities provide limited or no information on what climate change might mean to them, or are reporting in inconsistent ways.
This information deficit is driving what the Productivity Commission termed in their Low Emissions Economy report “an ongoing and systemic overvaluation of emissions-intensive activities”.
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.
Mandatory reporting of climate-related disclosures would help New Zealand meet its international obligations and achieve its target of zero carbon by 2050. It would also help to address climate change risks outlined in the National Climate Change Risk Assessment by making our financial system more resilient.
Organisations that would have to make disclosures
Around 200 entities in New Zealand would be required to produce climate-related disclosures.
- All registered banks, credit unions, and building societies with total assets of more than $1 billion.
- All managers of registered investment schemes with greater than $1 billion in total assets.
- All licensed insurers with greater than $1 billion in total assets under management or annual premium income greater than $250 million.
- All equity and debt issuers listed on the NZX.
Managers of registered investment schemes would be required to make disclosures on a fund-by-fund basis. This would ensure investors receive the information needed to understand the impact of climate change on the future performance of their investment.
Overseas incorporated organisations would be required to make disclosures if their New Zealand business is over the thresholds outlined above. This would ensure their New Zealand stakeholders’ needs are met.
The thresholds would be increased from time to time to reflect the movements in the consumers price index.
What reporting would require
Reporting would be against one or more standards that would be issued by the External Reporting Board (XRB). These standards would be developed in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).
The TCFD recommendations are structured around 4 thematic areas that represent core elements of how organisations operate:
- risk management, and
- metrics and targets.
The recommendations are considered international best practice for climate-related financial reporting and are already being used in New Zealand and other countries on a voluntary basis.
The XRB will prepare, consult on and issue new reporting standards for businesses required to disclose.
Elements of the disclosures relating to greenhouse gas emissions would be required to have independent assurance.
The Financial Markets Authority (FMA) would be responsible for independent monitoring, reporting and enforcement of the regime.
Some international organisations have begun producing good practice handbooks, case studies and guidance for reporting climate-related risks and opportunities using the TCFD recommendations.
- Climate measurement standards initiative financial disclosure guidelines(external link) — Climate Measurement Standards Initiative
- Pilot project on implementing the TCFD recommendations for banks(external link) — UNEP Finance Initiative
- Understanding physical climate risks and opportunities [PDF, 7.0 MB](external link) — The Institutional Investors Group on Climate Change
- Task force for climate-related financial disclosures knowledge hub(external link) — TCFD Knowledge Hub
Opportunities for public input
We encourage you to provide input at the Select Committee stage of the legislative process.
There will also be opportunities for stakeholder engagement when the XRB begins developing new standards and guidance material for producing climate-related disclosures.
- Climate-related financial disclosures discussion document(external link) - sets out our initial policy thinking — 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