Page last updated: 30 September 2022

Climate related disclosures

The New Zealand government has introduced a new regime making climate-related disclosures mandatory for some organisations. Organisations covered (known as Climate Reporting Entities or CREs) will have to make annual disclosures covering governance arrangements, risk management, strategies and metrics and targets for mitigating and adapting to climate change impacts. The requirement applies to the larger publicly listed companies, big insurers, banks, non-bank deposit takers and investment managers.

The FMA is responsible for independent monitoring and enforcement of the regime, providing guidance about compliance expectations, and reporting on monitoring activities and findings.

The FMA is taking a broadly educative and constructive approach to the new regime, issuing high level guidance on compliance expectations, then moving to a proactive regulatory role as the regime becomes more established.

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


Ethical finance4

Climate Reporting Entities (CREs) should make note of the following anticipated time-line

  1. July 2022 - XRB releases exposure draft of Climate Standards

  2. September 2022 - FMA publishes Initial Monitoring Approach

  3. December 2022XRB releases final Climate Standard

  4. January 2023 - First annual reporting periods for climate statements begin

  5. February 2023 – MBIE publishes Exposure Draft of recording keeping regulations for consultation

  6. June 2023 - FMA publishes detailed record keeping guidance

  7. April 2024 - First climate statements published

  • 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.
  • 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 statement that relates to the disclosure of GHG (Greenhouse Gas) emissions in the second year of reporting.
  • Make the climate statement available to the public.
  • Comply with record-keeping requirements.

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. The XRB intends to issue the following:

  • Aotearoa New Zealand Climate Standard 1: Climate-related Disclosures (NZ CS 1)
  • Aotearoa New Zealand Climate Standard 2: Adoption of Climate-related Disclosures (NZ CS 2)
  • Aotearoa New Zealand Climate-related Disclosures Concepts (NZ CRDC)

On the 28th of July, the XRB released an ‘exposure draft’ of the new Climate Standards.

You can read that draft and make submissions on the draft at the XRB site 

XRB will release its final Climate Standards at the end of 2022. The FMA will then begin regulating and monitoring the new CRD rules.

First annual reporting periods begin on January 1, 2023 for those Climate Reporting Entities with a January 1 balance date. All others begin from the start date of their next reporting period.

First climate statements will be published in 2024.

Read more about XRB’s approach to Climate Related Disclosures on their website 

Check the “What are Climate Reporting Entities (CREs)?” list above. For more technical questions determining whether your organisation is a CRE, or download the "Am I a Climate Reporting Entity?" fact sheet

We suggest seeking legal advice on whether your organisation is included. If you have further questions then contact us.


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.

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

The Financial Markets Authority (Levies) Regulations 2012, as amended in 2020 and 2022, set out the levies payable by industry. The levies are set by the Ministry of Business, Innovation, and Employment (MBIE).

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.


Consultation: Potential changes to the assurance requirement in the climate-related disclosures regime
Open consultation on potential changes to the assurance requirement in the climate-related disclosures regime.
Climate risks and the impact on financial statement audits
This document provides clarity for auditors about the expectations for information about climate risks in audit files.