New Zealand climate reporting rules: who must report and what the IFRS S2 roadmap changes

New Zealand's climate reporting rules currently operate on three different tracks. Existing climate reporting entities remain subject to the Aotearoa New Zealand Climate Standards (NZ CS). The Financial Markets Authority has given some entities no-action relief while Parliament considers a narrower statutory scope. Separately, the External Reporting Board is consulting on a possible transition to a standard based on International Financial Reporting Standard S2 (IFRS S2), with mandatory application proposed for 2033.

Those tracks should not be collapsed into one timetable. A no-action position describes how the Financial Markets Authority (FMA) intends to enforce the law; it does not amend the law itself. The draft roadmap from the External Reporting Board (XRB) is also a proposal. No final decision has been made to replace NZ CS.

The current position in one view

The safest order is law, relief, then roadmap. That sequence identifies the binding obligation before considering whether the regulator has temporarily changed its enforcement position or the standard setter may change the technical framework later.

Who is covered by the current law?

The current statutory definition covers large financial institutions and qualifying listed issuers. The FMA says the framework affects around 200 institutions, although the total can change as entities cross thresholds or receive exemptions.

Foreign issuers, overseas banks and overseas insurers may qualify for exemptions where equivalent reporting is available under another jurisdiction's framework. The precise tests and conditions matter, so a foreign group should not rely on the location of its parent company alone.

What a climate reporting entity must publish

A climate reporting entity (CRE) prepares an annual climate statement in accordance with the XRB standards, lodges it with the Companies Office and makes it publicly available. The reporting period follows the entity's accounting period. Climate statements are generally due within four months after the balance date.

NZ CS is made up of three connected standards. NZ CS 1 contains the climate-related disclosure requirements across governance, strategy, risk management, and metrics and targets. NZ CS 2 contains adoption provisions. NZ CS 3 sets general requirements, including the principles, methods and presentation rules that support the disclosures.

The statement needs to cover more than an emissions inventory. It includes oversight, climate-related risks and opportunities, anticipated impacts, scenario analysis, transition planning, greenhouse gas (GHG) emissions, targets and the methods used to produce material information. The sustainability reporting controls guide explains how to connect those disclosures to owners, source systems and review evidence.

Emissions assurance now forms part of the filing cycle

GHG emissions disclosures require assurance for reporting periods ending on or after 27 October 2024. The assurance practitioner reports on the parts of the climate statement that disclose emissions, rather than automatically assuring every climate disclosure to the same level.

Reporting teams therefore need to align the emissions boundary, calculation methods, source records and review timetable with the assurance engagement. The first year of assurance does not turn every underlying estimate into a directly measured value. It gives the reported emissions information an independent assurance process with a defined scope. The guide to limited and reasonable assurance explains the difference between assurance levels and evidence demands.

FMA relief changes enforcement, not the statute

The government has proposed removing managers of registered investment schemes from mandatory climate reporting and raising the listed issuer threshold from NZ$60 million to NZ$1 billion. It has also announced that life and health insurers will leave the framework. These changes are intended to be made through the Financial Markets Conduct Amendment Bill.

While that legislation remains incomplete, the FMA has adopted no-action positions for affected entities. For managed investment scheme (MIS) managers and smaller listed issuers expected to leave the framework, the position applies to specified obligations for the 2025/26 reporting period from 1 November 2025. Affected entities do not need to apply to use it.

A separate no-action position for life and health insurers began on 19 June 2026. It covers entities with balance dates from 31 March 2026 for the 2025/26 reporting period. The FMA says it will revisit the position if the law has not changed by the time those entities need to prepare for 2026/27.

No-action relief is a statement about the regulator's intended response to a breach. The FMA notes that it does not prevent third parties from taking action. An entity relying on relief should retain the scope analysis, the relevant reporting period and the FMA statement supporting that decision.

The proposed IFRS S2 transition is deliberately long

The XRB's July 2026 draft roadmap proposes a new standard called NZ IFRS S2 Climate-related Disclosures. It would adopt IFRS S2, consider harmonisation with Australia's AASB S2 framework and allow modifications for New Zealand's legal and market context.

Under the draft timetable, early adoption would be available from 1 October 2026. Mandatory application would begin on 1 January 2033, with entities able to continue using NZ CS during the transition. The consultation closes on 30 September 2026.

None of those dates is final. The XRB says feedback will determine whether the roadmap progresses and shape any future standard. If there is support, an exposure draft and further consultation would follow before NZ IFRS S2 is issued. The ISSB, IFRS S1 and IFRS S2 guide explains the international baseline, while the Australia climate reporting guide covers the framework the XRB intends to consider when addressing regional harmonisation.

NZ CS may also change before any IFRS S2 replacement

The longer roadmap does not freeze the current standards. The XRB is separately consulting on targeted amendments to NZ CS 1 covering investment-related Scope 3 emissions and exclusions from GHG emissions disclosures. That consultation closes on 29 July 2026.

This shorter process concerns the operation of the current standard. It should be tracked separately from the proposed 2033 transition because an amendment to NZ CS 1 could affect reporting much earlier than a future NZ IFRS S2 standard.

A practical filing sequence for 2026

1. Test the current statutory definition. Record the entity category, threshold calculation and accounting period.
2. Check exemptions and FMA relief. Match any reliance to the exact entity type and reporting period covered by the official notice.
3. Confirm the applicable standard. Unless and until another standard is issued and validly adopted, NZ CS remains the current reporting basis.
4. Build the filing calendar backwards. Include board review, assurance work, Companies Office lodgement and public release.
5. Keep reform planning separate. Model the proposed scope and IFRS S2 transition, but do not replace the current compliance file with a draft timetable.

New Zealand's immediate reporting answer still comes from the current statute and NZ CS. The two reform processes may change who reports and which standard they use, but they are not at the same stage. The next decisive events are enactment of the scope reforms, the close of the NZ CS 1 consultation and the XRB's response to its draft roadmap.

Sources

• Financial Markets Authority: Climate Reporting Entities
• Financial Markets Authority: no-action relief for CREs expected to leave mandatory reporting
• Financial Markets Authority: no-action relief for life and health insurers
• External Reporting Board: Aotearoa New Zealand Climate Standards
• External Reporting Board: draft climate reporting roadmap consultation
• External Reporting Board: proposed NZ CS 1 greenhouse gas emissions amendments
• Ministry of Business, Innovation and Employment: mandatory climate-related disclosures