New Zealand

Yes, there are mandatory climate-related disclosures based on the disclosure regime recommended by the TCFD. New Zealand was the first country to commit to making TCFD reporting mandatory and legislation establishing the climate reporting regime was passed in 2021.

NZX Limited (NZX) has a comply-or-explain regime for ESG disclosure, which applies to NZX-listed issuers of equity securities. 

The Financial Markets Authority (FMA) has published guidance that sets out its expectations from issuers of financial products that incorporate non-financial elements (such as terms like “ethical”, “responsible”, “sustainable”, “green” and ESG). 

Mandatory Climate Reporting

1. The Financial Markets Conduct Act 2013 (FMCA) requires certain entities to make prescribed climate-related disclosures. 
2. The regime applies to “Climate Reporting Entities” (CREs), comprising: large listed companies (with a market capitalisation of more than NZ$60 million), large registered banks, large licensed insurers, large credit unions, large building societies, and fund managers with significant assets under management (of more than NZ$1 billion).
3. CREs are required to prepare “climate statements” relating to their accounting periods. The climate statements must comply with the “climate-related disclosure framework”, which is made up of a series of “climate standards”. 
4. The climate-related disclosure regime took effect for accounting periods that started on or after 1 January 2023. This means (for example) that entities with a 30 June balance date prepared their respective first-year climate statement in relation to the accounting period ending 30 June 2024.  Those CREs are now required to prepare their second-year climate statement for the period ending 30 June 2025, to be published within four months of that balance date.
5. The External Reporting Board (XRB) is responsible for developing the climate standards, while the FMA is responsible for enforcing compliance with those standards.

NZX Corporate Governance Code & NZX Guidance

1. The NZX Corporate Governance Code (Code) provides recommendations in relation to corporate governance principles for NZX-listed issuers to report under the NZX Listing Rules. It operates on a comply-or-explain basis. 
2. One of the key aims of the Code is to promote issuer disclosure of ESG factors. In particular, one of the recommendations is that: “An issuer should provide non-financial disclosure at least annually, including considering environmental, social sustainability and governance factors and practices. It should explain how operational or non-financial targets are measured. Non-financial reporting should be informative, include forward looking assessments, and align with key strategies and metrics monitored by the board.”. Issuers may include other non-financial information, such as a description of the performance of an issuer’s business against strategic goals.
3. The NZX published an updated guidance note for issuers that are considering the disclosure of ESG factors under the Code (NZX Guidance). The note aims to help issuers better understand the benefits of ESG reporting and the global reporting regimes available. It also outlines good ESG practices and accepted frameworks for issuers to consider.

FMA Disclosure Framework

The FMA published a disclosure framework (FMA Disclosure Framework) for issuers of financial products that incorporate non-financial features (which the FMA refers to as “integrated financial products”). 

The requirement to prepare climate statements is mandatory for CREs.

The NZX recommendations apply on a comply-or-explain basis. 

The FMA Disclosure Framework applies to issuers of integrated financial products. It is not expressed as being mandatory in the strict sense, but is guidance from the FMA on how it intends to interpret the relevant provisions of the FMCA, hence is treated as effectively mandatory.

Mandatory Climate Reporting

CREs are required to prepare “climate statements” which must comply with the “climate-related disclosure framework” based on the TCFD Recommendations, covering governance, strategy, risk management, and metrics and targets. The framework is made up of a series of “climate standards” issued by the XRB.

NZX Corporate Governance Code & NZX Guidance

The NZX Guidance encourages good ESG practices for issuers to consider adopting when making ESG disclosures, focusing on the impact of ESG factors on business models, management of ESG risks and the transition to a low carbon economy.

FMA Disclosure Framework

The FMA Disclosure Framework outlines the type of disclosure that the FMA would expect to see from issuers of “integrated financial products”. It focuses on the “fair dealing” provisions in Part 2 of the FMCA and the framework notes that the fair dealing provisions apply broadly and the FMA will consider whether the conduct or disclosure is likely to mislead or confuse as perceived by an investor. The framework also focuses on how performance against non-financial factors is measured and evidenced, the monitoring and governance framework relevant to non-financial factors, and associated risks with the integrated financial products.

The climate-related disclosure reporting requirements have been developed in line with the TCFD Recommendations.

The NZX Guidance and FMA Disclosure Framework each refer to relevant international frameworks, but are not based on them. 

The mandatory climate reporting regime explicitly approaches materiality as double materiality. The New Zealand Climate Standard 3 (NZ CS 3) defines information as “material” if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users make on the basis of an entity’s climate-related disclosures. This broad definition of “materiality” requires an entity to consider the context within which it operates (i.e., an entity’s geographical location, its industry sector, or the state of the economy), whilst also considering the size of ESG impacts against the entity’s financial position, performance and cash flows.

The NZX Corporate Governance Code and NZX Guidance infer that the approach to materiality is single materiality. By way of example, the NZX Guidance specifies that issuers may wish to explain the relevance of ESG factors to their business, and the material ESG risks faced by the business.

The FMA Disclosure Framework infers that the approach to materiality is double materiality. The FMA expects an integrated financial system to require organisations to consider the impact of their activities on the environment, communities and individuals, alongside traditional financial factors. This also requires organisations to identify ESG risks for their business and to disclose how these will impact the business’ financial performance.

Yes, there are requirements for the disclosure of GHG emissions by CREs in their climate statements.

CREs must disclose Scope 1, Scope 2 (calculated using the location-based method) and Scope 3 emissions. Disclosure of Scope 3 emissions by each CRE in its first and second year of reporting is encouraged, but not required. A CRE may defer full disclosure of Scope 3 emissions until its third reporting year and the provision of comparative Scope 3 information until its fourth reporting year, where applicable transitional reliefs are used.

Under the mandatory climate reporting “climate standards”, the XRB recognises globally accepted standards, such as the GHG Protocol Corporate Accounting and Reporting Standard and ISO 14064-1, for GHG emissions measurement and reporting. However, the XRB does not mandate a specific GHG emissions measurement approach, but requires CREs to disclose the standards they use. The XRB has determined, through consultation and analysis, that different measurement standards can yield comparable results. Therefore, CREs must transparently disclose their chosen standards under the XRB's guidelines.

Mandatory climate reporting

Yes.

GHG disclosure included in climate statements must be subject to an assurance engagement, but there is no external assurance requirement for an entity’s first climate-related disclosure statement. For reporting years ending on or after 27 October 2024, each CRE in its second reporting year is now required to obtain independent assurance over their GHG emissions disclosures. However, CREs may apply a newly introduced exemption by the XRB to exclude Scope 3 GHG emissions from the scope of assurance for accounting periods ending before 31 December 2025. This relief is subject to disclosure conditions. Nevertheless, assurance remains mandatory for Scope 1 and Scope 2 emissions in the second reporting year. 

The assurance practitioner must comply with applicable standards when carrying out the assurance engagement (i.e., the Standard on Assurance Engagements 1 issued by the XRB on 3 August 2023). The assurance engagement can cover other parts of the climate-related disclosure as well, or the whole statement. 

The assurance report will need to be filed with the climate statements.

NZX Guidance / FMA Disclosure Framework

No assurance required. 

Yes. A number of non-CRE New Zealand entities have voluntarily included TCFD-based climate-related disclosures in their annual reporting. This voluntary inclusion has increased since 2019 when the New Zealand Government endorsed the TCFD Recommendations.

In respect of the NZX Guidance, it is also relatively common for NZX-listed issuers to include ESG disclosures in their annual reports. This disclosure is increasingly requested by investors.

It is also common in New Zealand for integrated financial products to be issued with ESG-related disclosures.

The three standards (listed above in section A.4) provide a taxonomy. In particular, NZ CS 3 establishes a glossary of defined terms as a taxonomy. The taxonomy exists within the mandatory reporting regime. It is described as an integral part of NZ CS 3. It includes definitions of key terms, such as “greenhouse gas”, “scope 1 emissions”, “scope 2 emissions”, and “scope 3 emissions”.

In July 2024, the Centre for Sustainable Finance: Toitū Tahua (CSF), an industry body, prepared a recommendations report for developing a sustainable finance taxonomy for New Zealand.  CSF had been tasked by the New Zealand Government to convene an Independent Technical Advisory Group to prepare and publish non-binding advice on the design of a taxonomy and to provide its recommendations to the Minister for Climate Change. 

Since July 2024, development of New Zealand’s sustainable finance taxonomy has progressed with ongoing work focused on key sectors. A public consultation on the taxonomy is now underway in mid-2025, focusing on defining clear criteria for sustainable activities.  The taxonomy is expected to be finalised later this year with an initial focus on the forestry and agricultural sectors.

The XRB has stated that it is committed to paying close attention to the ISSB’s work, including IFRS S1 and IFRS S2. The XRB has acknowledged the need to enable New Zealand entities to report in a globally consistent manner. To that end, they will continue to engage with the ISSB and monitor their work.

In May 2025, the XRB opened a request for information on the costs and benefits of aligning New Zealand climate reporting with international standards. That consultation closed on 13 June 2025.

A post-implementation review of New Zealand Climate Standards will commence in December 2025, where the XRB will consider aligning with requirements in international standards if they meet user needs and the objective of the New Zealand Climate Standards.

CREs have now completed first-year mandatory climate statements, marking a significant milestone in New Zealand’s climate-related disclosure regime. The FMA and XRB continue to play key roles in shifting the focus from preparation support to monitoring and enforcement.

In December 2024, the FMA released its first Insights Report on Climate-related Disclosures, highlighting common areas for improvement and best practices observed from the initial statements of CREs.

As CREs prepare their second-year climate statements for accounting periods commencing in 2024, the FMA’s insights and ongoing monitoring are expected to shape future guidance, enforcement priorities and regulatory enhancements.

Disclosure of current financial impacts of climate-related impacts is now mandatory for second-year climate statements and is likely to be an area of focus for the FMA’s monitoring activities.

New Zealand has not progressed dedicated modern slavery legislation, despite initial proposals under the former Labour-led Government. A draft legislative framework was consulted on in 2022, with broad support for introducing disclosure obligations and new measures to address exploitation in supply chains. However, the current National-led coalition Government has not prioritised the issue and has focussed on other areas of reform. In recent months, two separate Members’ Bills have been submitted, both of which propose modern slavery reporting requirements for businesses and steps to address exploitation in supply chains (one from National MP, Greg Fleming in relation to annual reporting and one from Labour MP, Camilla Belich proposing more extensive obligations, including referral duties). Given that Members’ Bills are only debated when drawn from a random ballot, the Bills have no guaranteed path forward unless selected in the ballot, or otherwise adopted by the Government.