Financial Markets Conduct (Climate-related Disclosures—Assurance Engagement) Exemption Notice 2025

The Financial Markets Conduct (Climate-related Disclosures—Assurance Engagement) Exemption Notice 2025 (Notice) concerns disclosure requirements for climate statements, or group climate statements, that climate reporting entities (CREs) are required to prepare under Part 7A of the Financial Markets Conduct Act 2013 (the Act).

Under section 461ZH(1) of the Act, climate reporting entities must ensure that the statements are, to the extent that the statements are required to disclose greenhouse gas (GHG) emissions, the subject of an assurance engagement.

This notice exempts CREs from that assurance duty in relation to the disclosure of information about scope 3 GHG emissions, which are a category of emissions identified and defined in Aotearoa New Zealand Climate Standard 1— Climate-related Disclosures. The exemption applies only to accounting periods ending before 31 December 2025 and is subject to the condition that certain information (outlined in clause 7(2) of the notice) be given to the Registrar of Companies at the time the climate statements are lodged with the Registrar.

The key reasons for granting the exemption are that –

• the exemption promotes confidence in financial markets by complementing the temporary relief that the External Reporting Board granted in November 2024, in particular the inclusion of adoption provision 8 in Aotearoa New Zealand Climate Standard 2—Adoption of Aotearoa New Zealand Climate Standards (NZ CS 2) to provide an optional delay of 1 year in assurance of scope 3 GHG emissions disclosures; and
• the exemption encourages climate reporting entities to disclose all or part of their scope 3 GHG emissions in year 2 of their climate reporting, which promotes informed participation in financial markets by enabling information about scope 3 GHG emissions to be available; and
• the exemption promotes fairness in year 2 of climate reporting between those climate reporting entities who use adoption provision 4 in NZ CS 2 to not disclose any scope 3 GHG emissions (thereby avoiding the assurance requirement) and those who choose not to rely wholly or in part on adoption provision 4 in NZ CS 2 and disclose all or part of their scope 3 GHG emissions, by not requiring those disclosures to be assured.

View Financial Markets Conduct (Climate-related Disclosures—Assurance Engagement) Exemption Notice 2025