Employers

New Zealand has introduced mandatory climate-related financial disclosures for large financial market participants, with reporting starting from 1 January 2023.

These rules aim to bring consistency, improve transparency around climate risks, and support New Zealand’s transition to a low-emissions economy.

What needs to be reported

Organisations must prepare climate-related disclosures as part of their annual reporting, aligned with Aotearoa New Zealand Climate Standards (developed by the XRB and based on TCFD recommendations).

Reports must cover:

• Governance: How climate-related risks are overseen and managed.
• Strategy: How climate risks and opportunities affect the business model and strategy.
• Risk management: Processes for identifying and managing climate risks.
• Metrics and targets: Emissions data and other metrics used to assess climate-related risks.

Greenhouse gas emissions reporting (Scope 1, 2, and later Scope 3) will also require independent assurance for accounting periods ending on or after 27 October 2024.

Who is required to report?

Roughly 200 entities are captured under the regime, including:

• Registered banks, credit unions, and building societies with assets over $1 billion
• Investment managers with assets under management over $1 billion
• Licensed insurers with total assets over $1 billion or annual premium income over $250 million
• Listed companies with equity or debt securities exceeding $60 million in market or face value
• Crown Financial Institutions with assets under management over $1 billion

Overseas incorporated companies with qualifying NZ operations are also included.

Oversight and Assurance

The Financial Markets Authority (FMA) is responsible for monitoring and enforcing compliance.
Disclosures will be phased in, with some standards initially optional to allow time for capability building.

• Independent assurance over GHG emissions will be required from late 2024.
• The government is consulting on expanding the assurance scope and related regulation.

What to do right now?

• Assess readiness – Understand your organisation’s obligations and gaps.
• Improve climate data collection – Begin building internal systems for tracking emissions.
• Establish governance processes – Assign responsibility and set up proper oversight.
• Understand the XRB climate standards – Familiarise your team with NZ CS 1, 2, and 3.