Last updated: May 26, 2026. New Zealand's mandatory sustainability reporting regime is best understood as a climate-related disclosure regime. It does not require every company in New Zealand to publish a full ESG or sustainability report. Instead, it requires certain large financial market participants, known as climate reporting entities, or CREs, to prepare annual climate statements using standards issued by the External Reporting Board, or XRB.
Short answer: New Zealand requires climate reporting entities to prepare annual climate statements for financial years commencing on or after January 1, 2023. The current regime applies to large banks, credit unions, building societies, licensed insurers, large listed issuers, and, under the current law, large managers of registered investment schemes. However, the Government has agreed reforms that are intended to take effect in 2026: the listed issuer threshold would rise from NZ$60 million to NZ$1 billion, and managed investment scheme managers would be removed from the mandatory climate reporting regime. FMA has also issued no-action relief for affected entities during the 2025/2026 reporting period while the law is being changed.
Who needs to report sustainability information in New Zealand?
The mandatory regime applies to climate reporting entities under Part 7A of the Financial Markets Conduct Act 2013. FMA and MBIE guidance describes the in-scope population as large financial market participants rather than all companies operating in New Zealand.
At a high level, the regime covers:
- registered banks, credit unions, and building societies with total assets of more than NZ$1 billion;
- licensed insurers with more than NZ$1 billion in total assets or more than NZ$250 million in annual premium income or annual gross premium revenue, depending on the relevant wording used for the entity type;
- large listed issuers of quoted equity securities or quoted debt securities, excluding growth-market issuers; and
- managers of registered investment schemes, other than restricted schemes, with more than NZ$1 billion in assets under management, subject to the reform discussed below.
The listed-issuer threshold is the part that is changing most visibly. Under the existing regime, a listed equity issuer is large where the market price of all quoted equity securities exceeds NZ$60 million, and a listed debt issuer is large where the face value of quoted debt exceeds NZ$60 million. Cabinet has agreed to raise both listed issuer thresholds to NZ$1 billion as part of the 2025 capital markets reforms.
What changed in 2025 and 2026?
New Zealand's climate reporting regime is in transition. MBIE says Cabinet agreed in October 2025 to adjust the climate-related disclosures regime by removing managed investment scheme managers from the regime, raising the listed issuer threshold from NZ$60 million to NZ$1 billion, adjusting liability settings, and enabling monetary thresholds to be raised by Order in Council.
As of late May 2026, the Financial Markets Conduct Amendment Bill is still shown by New Zealand Legislation as a bill reported from the Finance and Expenditure Committee on January 30, 2026. MBIE has stated that legislation to put the changes into effect is intended to pass in 2026. Because some entities may otherwise face uncertainty before the law is enacted, FMA has adopted a no-action approach for the 2025/2026 reporting period for affected entities that expect their climate reporting obligations to cease once the legislation is passed.
For a company checking its position now, the practical point is this: do not rely on an old New Zealand threshold article without also checking the reform status and FMA relief. Some entities that were previously CREs may soon leave the mandatory regime, while others remain fully in scope.
What climate reporting entities must prepare
A CRE must prepare an annual climate statement, or group climate statement where applicable, in accordance with the XRB climate standards. The statement is lodged on the Companies Office Climate-related Disclosures Register and made available to the public. Companies Office guidance says CREs lodge climate statements within four months of their balance date.
The XRB climate reporting framework is made up of three Aotearoa New Zealand Climate Standards:
- NZ CS 1 Climate-related Disclosures, which contains the main disclosure requirements;
- NZ CS 2 Adoption of Aotearoa New Zealand Climate Standards, which provides optional adoption provisions and transition relief; and
- NZ CS 3 General Requirements for Climate-related Disclosures, which sets the general principles and requirements for high-quality climate-related disclosures.
The disclosure areas broadly follow the TCFD structure: governance, strategy, risk management, and metrics and targets. In practice, this means a CRE needs to explain how its board and management oversee climate issues, how climate-related risks and opportunities affect the business or managed funds, how those risks are identified and managed, and what metrics and targets are used to track climate performance.
GHG emissions and assurance
GHG emissions are a central part of New Zealand climate statements. CREs need to disclose emissions information in line with the applicable New Zealand climate standards, including Scope 1, Scope 2, and, where required and not covered by available adoption relief, Scope 3 greenhouse gas emissions.
The regime also includes assurance. FMA guidance states that CREs must obtain independent assurance over the part of the climate statement that relates to GHG emissions for reporting years ending on or after October 27, 2024. This is not the same as a general consultant review: it is an assurance engagement over the GHG emissions disclosures.
There has been targeted relief for Scope 3 assurance because Scope 3 data can be difficult to collect and verify in early reporting cycles. In March 2026, FMA extended the temporary class exemption for two years to complement XRB relief for assurance of Scope 3 GHG emissions disclosures. Companies should still build Scope 3 data processes early, because relief from assurance is not the same as relief from understanding value-chain emissions.
What if your company is not a climate reporting entity?
Many New Zealand businesses are not directly required to publish climate statements under the CRD regime. That does not mean they will avoid sustainability data requests. Banks, insurers, listed companies, large customers, government buyers, and overseas parent companies may still ask suppliers or portfolio companies for GHG emissions data, energy information, climate-risk inputs, policies, targets, and evidence.
This is especially relevant where a customer is preparing Scope 3 emissions, a lender is reviewing climate-related credit risk, or a parent company is preparing reporting under New Zealand, Australian, European, ISSB-based, or customer-specific requirements. For these companies, the right first step is to understand the actual request wording before building a full report.
If the trigger is a customer, lender, or investor request rather than direct New Zealand legal applicability, Keslio's supplier request support can help translate the request into a practical data and evidence workplan.
How to prepare for New Zealand climate reporting
CREs and companies close to the thresholds should build the reporting process around governance, data quality, and evidence, not just drafting. A practical workplan usually includes:
- confirming whether the entity is currently a CRE and whether the 2025-2026 reforms or no-action relief affect its position;
- mapping the reporting boundary, subsidiaries, funds, New Zealand business presence, and any group reporting relationships;
- assigning owners across finance, risk, legal, operations, facilities, investment, procurement, HR, and sustainability teams;
- collecting Scope 1 and Scope 2 data, including fuels, refrigerants, electricity, and renewable energy instruments where relevant;
- screening Scope 3 categories and identifying which value-chain data is needed from suppliers, investees, customers, logistics providers, landlords, or portfolio companies;
- documenting emissions calculation methods, emission factors, assumptions, boundaries, exclusions, controls, and evidence files;
- developing climate risk and opportunity registers across transition risk, physical risk, and relevant time horizons;
- connecting climate issues to governance, strategy, risk management, metrics, targets, financial planning, and decision-making; and
- preparing for assurance by keeping records that a reviewer can trace from the climate statement back to source data.
Common mistakes to avoid
- Assuming the regime applies to every company. New Zealand's mandatory regime is focused on CREs, though private companies may still receive customer or finance-sector requests.
- Using the old NZ$60 million listed issuer threshold without noting the reform. The current legislative framework and the intended 2026 reforms need to be checked together.
- Ignoring FMA's no-action relief. Some entities expected to leave the regime may be treated differently during the 2025/2026 period, but this should be confirmed carefully.
- Waiting until the climate statement is due. Climate statements must be evidence-backed and lodged within a defined window, so data collection needs to start well before balance date.
- Treating Scope 3 relief as a reason to ignore suppliers. Scope 3 data remains strategically important for customers, lenders, investors, and future reporting readiness.
How Keslio can help
Keslio helps companies turn climate and sustainability reporting requirements into practical workstreams. For New Zealand, this can include:
- applicability checks for CRE status, threshold exposure, reform impact, and supplier-request situations;
- GHG emissions calculations for Scope 1, Scope 2, and relevant Scope 3 categories;
- data request templates and evidence trackers for finance, operations, facilities, procurement, HR, investment, and logistics teams;
- climate disclosure gap reviews across governance, strategy, risk management, and metrics and targets;
- methodology notes for boundaries, emission factors, exclusions, assumptions, and data limitations;
- assurance-readiness support for GHG emissions disclosures;
- sustainability reporting and communications for climate statements, internal drafts, or voluntary sustainability reporting; and
- supplier request support where the reporting trigger comes from a customer, lender, investor, or parent company.
This guide is not legal advice. If your company is determining formal CRE status, threshold treatment, no-action relief, exemption eligibility, or interpretation of New Zealand law, legal counsel, company secretarial advisers, auditors, or the relevant regulator should confirm the obligation while Keslio supports the ESG data, calculations, reporting, and evidence workstream.
Sources and further reading
- FMA guidance on climate reporting entities
- FMA no-action relief for CREs expected to leave the regime
- MBIE guidance on mandatory climate-related disclosures and 2025 capital markets reforms
- FMA update on Scope 3 GHG assurance exemption relief
- Companies Office guidance on lodging climate statements
- XRB climate-related disclosures resources
- XRB NZ CS 3 General Requirements for Climate-related Disclosures
- Financial Markets Conduct Amendment Bill status on New Zealand Legislation
