New Zealand narrows the scope of climate-related disclosures

As regulatory landscapes evolve globally, New Zealand is moving to recalibrate its climate-related reporting obligations. Recent policy announcements signal a shift in the balance between regulatory scope and proportionality, particularly for smaller listed entities and investment managers.

The Government of New Zealand has announced significant amendments to the climate-related disclosures (CRD) regime and capital markets reforms aimed at recalibrating the balance between transparency and cost for listed issuers.

Thresholds revised for listed issuers

Under the prior regime, listed equity issuers with a market capitalisation of at least $60 million, and debt issuers with a total face value of quoted debt of at least $60 million, were subject to mandatory climate reporting. The revised policy increases this threshold to $1 billion for both equity and debt issuers. In practical terms, the population of climate-reporting entities (CREs) is projected to decline from approximately 164 to 76, with 66 listed companies and 22 managed investment scheme (MIS) managers exiting the regime.

Design adjustments to liability and scope

In addition to the threshold increase, the Government will adjust director and company liability settings so as to reduce “unnecessary risk and cost” while preserving robust disclosure. The climate-reporting regime will also remove MIS managers from scope, reflecting stakeholder feedback that those disclosures did not meaningfully inform investment decisions.

Interim relief from regulatory enforcement

In recognition of the legislative lag between announcement and enactment, the Financial Markets Authority (FMA) has set out a "no-action" approach for affected CREs from 1 November 2025. For the 2025/2026 reporting period, entities expecting to be relieved of mandatory reporting should note that the FMA does not intend to take enforcement action under Part 7A of the Financial Markets Conduct Act 2013 (FMC Act) if they fail to lodge climate statements. The relief does not apply to entities with a 30 June 2025 balance date, as their preparations were already well under way by the time of the Government decision.

Additional reforms to capital markets disclosure

Alongside the climate reporting changes, the Government also introduced reforms to reduce listing costs and improve transparency around private asset investment. Since June 2025, initial public offerings are no longer required to provide prospective financial information (PFI), thereby lowering barriers to listing. Furthermore, from March 2027, fund managers will be required to disclose whether assets are invested in New Zealand or overseas, and to categorise assets (for example, debt, infrastructure, unlisted equities).

Implications for reporting entities and investors

From a reporting-entity perspective, companies and MIS managers that no longer meet the new threshold will exit the mandatory CRD regime, reducing compliance burden and cost. At the same time, larger entities remain subject to disclosure, preserving the materiality of climate-risk information. From an investor standpoint, clearer disclosure of private-asset allocations enhances transparency across the investment ecosystem.

Conclusion

In summary, New Zealand’s regulatory reset adjusts the scope and costs of mandatory climate reporting while maintaining disclosure robustness for large issuers. The changes reflect feedback from market participants on cost-effectiveness and listing attractiveness, and provide interim regulatory relief while legislative amendments take shape.