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Page last updated: 29 April 2025

Climate Reporting Entities (CREs)

The Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021 amended the Financial Markets Conduct Act 2013 (FMC Act), the Financial Reporting Act 2013, and the Public Audit Act 2001. The new law requires around 200 large financial institutions covered by the FMC Act to start making climate-related disclosures.

Affected organisations are required to publish disclosures from financial years commencing on or after 1 January 2023, in accordance with climate standards published by the External Reporting Board (XRB). The organisations are known as Climate Reporting Entities.

  • All registered banks, credit unions, and building societies with total assets of more than $1 billion.
  • All managers of registered investment schemes (other than restricted schemes) with greater than $1 billion in total assets under management.
  • All licensed insurers with greater than $1 billion in total assets or annual premium income greater than $250 million.
  • Listed issuers of quoted equity securities with a combined market price exceeding $60 million.
  • Listed issuers of quoted debt securities with a combined face value of quoted debt exceeding $60 million.
  • Authorised Bodies, who are managers of registered schemes and operate under the licence of another manager, where the total assets under that licensee (including assets of all authorised bodies) exceeds $1 billion.

Sign up for climate-related disclosure news and updates by selecting Climate Reporting Entity (CRE) information from the subscription checklist.

Use these flowcharts to help determine if your organisation is a Climate Reporting Entity:

These charts are only for guidance. They should not be considered to be, or relied on as, legal advice.
Please ensure you undertake your own due diligence.

For more technical questions determining whether your organisation is a CRE, download the "Am I a Climate Reporting Entity?" fact sheet. 

The climate-related disclosures legislation gives the External Reporting Board (XRB) a mandate to develop and issue climate standards as part of a climate-related disclosures framework. 

XRB has released its final Climate Standards. View the Climate Standards from XRB.

They are:

  • Aotearoa New Zealand Climate Standard 1: Climate-related Disclosures (NZ CS 1)
  • Aotearoa New Zealand Climate Standard 2: Adoption of Aotearoa New Zealand Climate Standards (NZ CS 2)
  • Aotearoa New Zealand Climate Standard 3 – General Requirements for Climate-related Disclosures (NZ CS 3)

The Aotearoa New Zealand Climate Standards apply to reporting periods beginning on or after 1 January 2023.

First climate statements will be published in 2024.

  • Prepare an annual climate statement that discloses information about the effects of climate change on their business or any fund they manage.
  • Prepare climate statements in accordance with climate standards issued by the XRB.
  • Obtain independent assurance about the part of the climate statements that relates to the disclosure of greenhouse gas (GHG) emissions for reporting years ending on or after 27 October 2024.
  • Make the climate statement available to the public.
  • Comply with record-keeping requirements.

 

An exemption has been granted to provide relief for certain overseas entities with a secondary listing on a financial product market operated by NZX Limited from climate reporting, assurance, and record-keeping duties under Part 7A of the Financial Markets Conduct Act 2013 (the Act). 

The notice provides a complete exemption from the requirements if the entity does not have a 'large presence' (as defined in the exemption notice) in New Zealand. The notice also provides an exemption from the requirements to the extent that a subsidiary or related body corporate of the entity is required by the Act to comply with climate reporting, assurance, and record-keeping requirements for the entity’s New Zealand business. 

Finally, the notice provides a partial exemption for an entity that has a large presence in New Zealand. The exemption ensures that the entity is only required to comply with the climate reporting, assurance, and record-keeping requirements under the Act for its New Zealand business or New Zealand-based investment assets. 

The notice includes conditions requiring alternative disclosure and reporting. 

View the Financial Markets Conduct (Climate-related Disclosures for Foreign Listed Issuers) Exemption Notice 2024

Financial Markets Conduct (Climate-related Disclosures—Overseas Banks and Insurers) Exemption Notice 2024 

The Financial Markets Conduct (Climate-related Disclosures—Overseas Banks and Insurers) Exemption Notice 2024 concerns overseas registered banks and overseas licensed insurers that are climate reporting entities under Part 7A of the Financial Markets Conduct Act 2013. Those entities are exempted from the requirement to have their climate statements, or group climate statements, dated and signed by their directors. 

The conditions of the exemption provide for: 

  • the climate statements or group climate statements to be dated and signed by the exempt entity’s New Zealand chief executive officer; and 
  • certain information to be given to the Registrar of Companies.  

The notice commenced on 29 July 2024 and continues until 3 November 2026. 

We are planning a full review of the method of execution of financial statements and climate statements by overseas entities prior to the expiry of this notice for climate statements and the Financial Markets Conduct (Overseas Registered Banks and Licensed Insurers) Exemption Notice 2021 for financial statements, which expires in November 2026 

We have also published a Regulatory Impact Statement (RIS) that discusses the exemption relief in the Financial Markets Conduct (Climate-related Disclosures—Overseas Banks and Insurers) Exemption Notice 2024. It summarises the problem we are seeking to address, our objectives, the options and their associated impacts, and the consultation process we undertook before deciding to grant the exemption. 

We’ve published our initial monitoring approach to climate-related record keeping - to inform and support new climate reporting entities to meet their statutory reporting requirements.

Download the Climate-related disclosure record keeping: our initial approach PDF

This plan provides a summary of our approach to monitoring the compliance of CREs with the legislative requirements under the FMC Act and reporting obligations under the CRD framework. It is primarily intended for CREs, their directors and other authorised bodies.

Download the Climate-related Disclosures Monitoring Plan 2023-2026 

The Financial Markets Authority (Levies) Regulations 2012 set out the levies payable by industry. The levies are set by Regulation on the recommendation of the Minister of Commerce and Consumer Affairs. This recommendation is based on advice from the Ministry of Business, Innovation, and Employment.

This document outlines the levies related to the new Climate Related Disclosures regime.

The regulations relate to a climate reporting entities obligations under the Financial Markets Conduct Act 2013 (as amended by the CRD Act), and prescribes –  

  1. the manner in which climate-related disclosure records are to be kept;
  2. how climate-related disclosure records are to be made available for inspection; and
  3. sets infringement fees for non-compliance.

Please note, these regulations come into force on 2 October 2023.

Read the Financial Market Conduct (Climate-related Disclosures) Amendment Regulations 2023 (SL 2023/222)

An exemption has now been granted to provide relief for certain climate reporting entities (CREs). The relief comprises a class exemption for five years for each CRE, whether incorporated in New Zealand or overseas, which is in liquidation, receivership or voluntary administration (VA), and for schemes or funds in wind up, from the duties in Part 7A of the Financial Markets Conduct Act (FMC Act), comprising:  

  • CREs in liquidation – full relief
  • Registered schemes or funds in wind-up – full relief
  • CREs in receivership or VA – relief applies for the reporting year in which the receivership or VA appointment is made and for the next 2 reporting periods. 

The relief is from the whole of Part 7A of the FMC Act (and any corresponding Regulations) including: 

  • record-keeping obligations
  • the requirement to prepare and lodge climate statements or group climate statements
  • the requirement to link to the climate statements in the annual report
  • the requirement to obtain an assurance engagement in relation to the climate statements. 

The notice comes into force on 30 November 2024. 

View the Financial Markets Conduct (Climate Reporting Entities in Liquidation, Wind-up, or External Administration) Exemption Notice 2024  

View the Exemption Notice on the Legislation New Zealand website 

We have also published a Regulatory Impact Statement that discusses the exemption relief and summarises the problem we are seeking to address, our objectives, the options and their associated impacts, and the consultation process we undertook before deciding to grant the exemption relief.   

Download the Regulatory Impact Statement - Exemptions for Climate Reporting Entities in Liquidation, Wind-up, or External Administration [PDF 595KB]

Quick links to important documents

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