New Zealand's Climate Disclosure Rules: What You Need to Know

New Zealand climate disclosure at a glance

New Zealand's External Reporting Board (XRB) issued the Aotearoa New Zealand Climate Standards (NZ CS 1, NZ CS 2 and NZ CS 3) in December 2022, requiring 164 large financial market participants, including listed issuers, banks and insurers, to publish annual climate statements for reporting periods beginning on or after 1 January 2023.

New Zealand legislated climate disclosure ahead of Australia, Hong Kong and Singapore, and is now recalibrating: in October 2025 Cabinet agreed to raise the listed-issuer threshold from $60 million to $1 billion, with legislation before Parliament in 2026.

Here's what you need to know.

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What New Zealand's climate disclosure rules require

Climate reporting entities must prepare annual climate statements that comply with three XRB standards, lodged on the Companies Office Climate-related Disclosures Register.

• NZ CS 1 (Climate-related Disclosures): the core disclosure standard, structured on the four pillars of governance, strategy, risk management, and metrics and targets. It requires scenario analysis, disclosure of gross Scope 1, Scope 2 and Scope 3 GHG emissions in tonnes of CO2e, and transition planning.

• NZ CS 2 (Adoption Provisions): a set of time-limited exemptions that phase in the hardest disclosures, including Scope 3 emissions, anticipated financial impacts and Scope 3 assurance. The XRB extended these provisions by two years in November 2025.

• NZ CS 3 (General Requirements): the principles underpinning fair presentation, materiality and comparability across climate statements.

• Measurement standard: NZ CS 1 is a disclosure standard, and the XRB did not mandate a single measurement method. Entities must state which standard their GHG emissions are measured against; the GHG Protocol Corporate Accounting and Reporting Standard (2004) and ISO 14064-1 are the two the XRB names.

The standards are secondary legislation under the Legislation Act 2019. The disclosure duty itself sits in Part 7A of the Financial Markets Conduct Act 2013, inserted by the Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021.

Who is in scope

Four classes of large financial market participants are climate reporting entities under current law, with the population set to shrink by more than half under changes agreed in October 2025.

In scope today

1. Listed issuers: equity issuers with market capitalisation above $60 million and debt issuers with quoted debt above $60 million face value. Issuers on growth markets are excluded.

2. Banks, credit unions and building societies: total assets above $1 billion.

3. Licensed insurers: total assets above $1 billion or annual gross premium revenue above $250 million.

4. Managers of registered investment schemes: more than $1 billion in total assets under management.

Overseas incorporated organisations report when their New Zealand business exceeds these thresholds.

Agreed changes before Parliament

Cabinet agreed in October 2025 to raise the listed-issuer threshold to $1 billion (both equity and debt) and to remove investment scheme managers from the regime entirely. The Cabinet paper estimates 34 listed issuers remain at the $1 billion threshold, against ~100+ today.

Legislation through the Financial Markets Conduct Amendment Bill is intended to pass in 2026. In the interim, the FMA has applied a no-action approach since 1 November 2025: it will not act against exiting entities that stop preparing climate statements while the Bill is before Parliament.

Supply-chain reach. The rule is clear that only entities above the thresholds have to report. Our read for non-reporters: the obligation reaches further than the register suggests. Scope 3 covers value-chain emissions, so a reporting entity is likely to engage its suppliers for emissions data, and those suppliers are typically companies that don't appear on the register themselves.

If you sell to a New Zealand listed issuer, bank or insurer, prepare for carbon data requests even if you have no direct reporting duty.

Key dates and milestones

New Zealand's standards are moving closer to the global ISSB baseline

New Zealand built its own climate standards before the global ones existed, and is now working to bring them into line. The regulatory fact today: NZ CS 1 is the standard you report against, not IFRS S2.

Context: the XRB wrote NZ CS 1, 2 and 3 in 2021 and 2022. The new global climate disclosure standard, IFRS S2, was released in June 2023, after New Zealand had already finished. Both standards are built on the same foundation, the TCFD framework, so they look similar. However, they are not identical: IFRS S2 asks for more in some areas (it requires companies to use the GHG Protocol to measure emissions, and to report an emissions intensity figure and, for banks and insurers, financed emissions), while NZ CS 1 is stricter in a few places (it spells out which climate scenarios must be modeled, for example).

What comes next: the XRB has said it wants to close the gap. After asking the market for views, it is planning to revise NZ CS to align more closely with IFRS S2, rather than scrap the current standard and start again. The XRB is targeting public consultation in 2026 and updated standards in 2027.

What this means in practice: an entity already reporting under NZ CS 1 has done most of the work that a future IFRS S2-aligned version will ask for. The likely additions are formalising GHG Protocol measurement and adding an intensity metric, for example. None of that requires waiting for 2027. A clean, GHG Protocol-based inventory built now carries straight into the revised requirements.

How companies should prepare

The entities staying in scope have cleared first-round reporting. The work now is the second phase: Scope 3 and expanded assurance, both arriving for periods ending from late 2027.

1. Establish your full GHG inventory now. Scope 3 disclosure becomes mandatory from your fifth reporting period. Building supplier data collection, emission factor selection and category boundaries takes longer than one annual cycle.

2. Map your value-chain exposure to the remaining reporters. Suppliers to New Zealand's listed issuers, banks and insurers will receive emissions data requests regardless of their own size. Treat a customer's FY2027 Scope 3 deadline as your own.

3. Build assurance-ready processes early. Scope 1 and 2 assurance is already mandatory, and Scope 3 assurance applies to periods ending on or after 31 December 2027. Assurance practitioners working under NZ SAE 1 will ask where every number came from; an audit trail built retroactively is the expensive version.

4. Build on the frameworks you already use. NZ CS 1 follows the TCFD's four pillars, and GHG Protocol-based inventories carry directly into the disclosure. Work done for CDP, ISSB-aligned regimes or Australian reporting transfers.

How Terrascope can help

Terrascope's AI-powered platform helps companies operating in New Zealand and across Asia-Pacific move from baseline emissions data to audit-ready disclosures, including Dyno Nobel, who achieved limited assurance over their global emissions data one year ahead of mandate.

• Scope 1, 2, and 3 emissions measurement. Your emissions data flows in automatically from source systems, monthly and auditable, covering the full inventory NZ CS 1 requires.

• Audit-ready reporting. Every step is traceable from data entry to disclosure, with assurance-provider access built in for engagements.

• Supply-chain intelligence. See what your Scope 3 data is telling you before the FY2027 disclosure deadline turns it into a published number.

• Multi-framework alignment. From framework to finished report: AI-drafted, team-reviewed disclosures aligned to TCFD-based standards like NZ CS 1 and ISSB-aligned regimes across the region.

Frequently asked questions

Need to get ahead of New Zealand's reporting requirements? Speak to a Terrascope expert today.