New Zealand’s mandatory climate-related disclosure regime has been operating since reporting periods beginning on or after January 1, 2023. In 2026, climate reporting entities still need to apply the New Zealand Climate Standards while tracking proposed legislation that could narrow the regime’s scope.
The key control is legal status: separate requirements already in force, regulatory relief currently available, and government changes that still need legislation.
Who is a climate reporting entity today
The Financial Markets Authority describes the current regime as covering approximately 200 entities. Subject to detailed statutory tests, climate reporting entities include:
- Registered banks, credit unions, and building societies with total assets above NZ$1 billion.
- Managers of registered investment schemes with more than NZ$1 billion in total assets under management.
- Licensed insurers with total assets above NZ$1 billion or annual premium income above NZ$250 million.
- Listed equity issuers with quoted equity market capitalisation above NZ$60 million.
- Listed debt issuers with quoted debt securities with a total face value above NZ$60 million.
Entities should apply the Financial Markets Conduct Act definitions and FMA guidance to their own structure. A change announced by government does not alter the current statutory test until legislation takes effect or valid regulatory relief applies.
NZ CS 1 defines the climate disclosures
NZ CS 1 requires disclosure across governance, strategy, risk management, and metrics and targets. It works with NZ CS 2, which provides adoption provisions, and NZ CS 3, which contains general requirements and principles.
The regime focuses on climate-related risks and opportunities rather than the broader range of sustainability matters addressed by IFRS S1. Multinational groups should create a crosswalk between NZ CS and the ISSB global baseline rather than using one framework’s index for both.
New Zealand disclosures also include scenario analysis and greenhouse gas emissions. Preserve source assumptions, methods, models, review evidence, and the connection between climate analysis and business decisions.
Assurance already applies to GHG disclosures
Mandatory assurance over greenhouse gas emissions disclosures began for accounting periods ending on or after October 27, 2024. The XRB’s assurance standard and related FMA oversight make evidence quality an immediate requirement, not a future aspiration.
Reconcile the emissions boundary to the reporting entity, maintain a complete source population, version calculation methods and factors, and retain evidence of review. Use an assurance-readiness assessment to find control gaps, while applying New Zealand’s specific assurance requirements for the formal engagement.
In 2026, XRB and FMA relief affects aspects of Scope 3 assurance. Confirm the exact period and conditions before relying on it, and document the conclusion in the report file.
Proposed scope changes are not yet the default rule
The government agreed in October 2025 to pursue changes to the statutory regime. The proposals include removing managed investment scheme managers from mandatory scope, raising the listed-issuer threshold from NZ$60 million to NZ$1 billion, and adjusting director liability settings.
The government indicated that legislation would be progressed in 2026. The FMA has also provided no-action relief for certain entities expected to fall outside the proposed future scope.
A no-action position is not the same as repeal of the underlying law. An entity considering relief should confirm eligibility, conditions, duration, board approval, and any disclosure still expected. Preserve the analysis and monitor the legislation until commencement.
A 2026 compliance decision tree
First, test whether the entity meets the current statutory definition. If it does, determine whether an exemption or FMA no-action position applies. If neither applies, continue full NZ CS reporting and assurance. If relief may apply, obtain advice and document every condition before changing the reporting plan.
Regardless of the scope outcome, preserve reusable climate data and governance. Banks, customers, investors, overseas parents, or other jurisdictions may still need the same information even if New Zealand’s statutory boundary changes.
Strengthen the system during regulatory change
Use the uncertainty to simplify duplicated controls, not to abandon the inventory. Maintain one GHG inventory management plan, one evidence index, and one register of reporting requirements. Tag each output to the data it uses and the legal or voluntary reason it is produced.
Information in this article was verified on August 9, 2026. Proposed legislation and regulatory relief may change. This overview is general information, not legal advice.
Sources
See how Carbon Impact automates compliance with standards like this.