New Zealand

Yes. There are mandatory climate-related disclosures based on the disclosure regime recommended by the TCFD. New Zealand was the first country to commit to making TCFD reporting mandatory and legislation establishing the climate reporting regime was passed in 2021.

NZX Limited (NZX) has a comply-or-explain regime for ESG disclosures, which applies to NZX-listed issuers of equity securities. 

The Financial Markets Authority (FMA) has published guidance that sets out its expectations for issuers of financial products that incorporate non-financial elements (such as terms like “ethical”, “responsible”, “sustainable”, “green” and “ESG”). 

Mandatory Climate Reporting

The Financial Markets Conduct Act 2013 (FMCA) requires certain entities to make prescribed climate-related disclosures. The regime applies to “Climate Reporting Entities” (CREs), comprising:

a. large listed companies (with a market capitalisation of more than NZ$60 million);

b. large registered banks, large licensed insurers, large credit unions, large building societies; and

c. fund managers with significant assets under management (of more than NZ$1 billion).

In October 2025, as part of broader changes intended to reduce compliance burdens and strengthen New Zealand's capital markets, the Government announced changes (the CR Amendments) that will:

a. raise the market capitalisation threshold for listed issuers from NZ$60 million to NZ$1 billion;

b. remove health and life insurers from climate reporting obligations;

c. remove Managed Investment Scheme managers from the regime; and

d. grant relief to certain overseas entities subject to a comparable mandatory overseas climate reporting regime from reporting, assurance and record-keeping duties under Part 7A of the FMCA. Australia is the first approved jurisdiction under this exemption.

This will significantly reduce the number of CREs. It is intended that legislation to put these changes into effect will be passed in 2026.

CREs are required to prepare “climate statements” relating to their accounting periods. The climate statements must comply with the “climate-related disclosure framework”, which is made up of a series of “climate standards”. 

The climate-related disclosure regime took effect for accounting periods that started on or after 1 January 2023. This means (for example) that entities with a 30 June balance date were required to prepare their first-year climate statements in relation to the accounting period ending 30 June 2024, and their second-year climate statements for the period ending 30 June 2025. Remaining CREs are now preparing their third-year climate statements for the period ending 30 June 2026, to be published within four months of that balance date.

The External Reporting Board (XRB) is responsible for developing the climate standards, while the FMA is responsible for enforcing compliance with those standards.

NZX Corporate Governance Code and NZX Guidance

The NZX Corporate Governance Code (Code) provides recommendations in relation to corporate governance principles for NZX-listed issuers to report under the NZX Listing Rules. It operates on a comply-or-explain basis. 

One of the key aims of the Code is to promote issuer disclosure of ESG factors. In particular, one of the recommendations is that: “An issuer should provide non-financial disclosure at least annually, including considering environmental, social sustainability and governance factors and practices. It should explain how operational or non-financial targets are measured. Non-financial reporting should be informative, include forward looking assessments, and align with key strategies and metrics monitored by the board”. Issuers may include other non-financial information, such as a description of the performance of their businesses against strategic goals.

NZX published an updated guidance note for issuers that are considering the disclosure of ESG factors under the Code (NZX Guidance). The note aims to help issuers better understand the benefits of ESG reporting and the global reporting regimes available. It also outlines good ESG practices and accepted frameworks for issuers to consider.

FMA Disclosure Framework

In 2026, the FMA published an updated sustainability-related disclosure guidance (FMA Disclosure Framework), replacing and operationally expanding the 2020 FMA Disclosure Framework. The FMA Disclosure Framework provides concrete examples based on four key principles: (i) claims need to be clear; (ii) substantiate your claims; (iii) messages need to be consistent; and (iv) third-party involvement is effectively managed.

The requirement to prepare climate statements is mandatory for CREs. Certain provisions are subject to temporary relief: disclosure of current financial impacts and transition plan aspects of strategy became mandatory in the second year of reporting, and anticipated financial impacts and Scope 3 GHG emissions will become mandatory in the fifth year of reporting.

CREs that will fall outside the mandatory regime under the upcoming CR Amendments may choose to continue to produce climate statements on a voluntary basis after the amending legislation is enacted and the thresholds for reporting are changed. The FMA has confirmed a “no action” approach for affected entities while amending legislation passes (expected in 2026). However, the “fair dealing” provisions in Part 2 of the FMCA continue to apply to representations made in any voluntary reporting.

NZX’s recommendations apply on a comply-or-explain basis. 

The FMA Disclosure Framework applies to issuers of integrated financial products. It is not expressed as being mandatory in the strict sense, but is guidance from the FMA on how it intends to interpret the relevant provisions of the FMCA, and is hence treated as effectively mandatory.

Mandatory Climate Reporting

CREs are required to prepare climate statements which must comply with the “climate-related disclosure framework” based on the TCFD Recommendations, covering governance, strategy, risk management, and metrics and targets. The framework is made up of a series of “climate standards” issued by the XRB.

NZX Corporate Governance Code & NZX Guidance

The NZX Guidance encourages good ESG practices for issuers to consider adopting when making ESG disclosures, focusing on the impact of ESG factors on business models, management of ESG risks and the transition to a low carbon economy.

FMA Disclosure Framework

The FMA Disclosure Framework outlines the type of disclosure that the FMA would expect to see from issuers of “integrated financial products”. It focuses on the “fair dealing” provisions in Part 2 of the FMCA and the framework notes that the fair dealing provisions apply broadly and the FMA will consider whether the conduct or disclosure is likely to mislead or confuse as perceived by an investor. The FMA Disclosure Framework also focuses on how performance against non-financial factors is measured and evidenced, the monitoring and governance framework relevant to non-financial factors, and risks associated with the integrated financial products.

The climate-related disclosure reporting requirements have been developed in line with the TCFD Recommendations.

The NZX Guidance and FMA Disclosure Framework each refer to relevant international frameworks, but are not based on them. 

However, the XRB has launched a consultation on a draft roadmap that foresees the adoption of IFRS S2. The draft roadmap proposes issuing a new climate standard (NZ IFRS S2 Climate-related disclosures), which will be internationally aligned by adopting IFRS S2 as its basis and harmonised with Australia’s reporting obligations under AASB S2 Climate-related Disclosures and the Australian Corporations Act 2001. Comments on the draft roadmap are requested by 30 September 2026. If adopted, mandatory application of NZ IFRS S2 would commence from 2033.

The mandatory climate reporting regime explicitly approaches materiality as double materiality. The New Zealand Climate Standard 3 (NZ CS 3) defines information as “material” if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users make on the basis of an entity’s climate-related disclosures. This broad definition of “materiality” requires an entity to consider the context within which it operates (i.e., an entity’s geographical location, its industry sector, or the state of the economy), whilst also considering the size of ESG impacts against the entity’s financial position, performance and cash flows.

The Code and NZX Guidance indicate that the approach to materiality is single materiality. By way of example, the NZX Guidance specifies that issuers may wish to explain the relevance of ESG factors to their business, and the material ESG risks faced by the business.

Yes, there are requirements for the disclosure of GHG emissions by CREs in their climate statements.

CREs must disclose Scope 1, Scope 2 (calculated using the location-based method) and Scope 3 emissions. Originally, a CRE may defer full disclosure of Scope 3 emissions until its third reporting year and the provision of comparative Scope 3 information until its fourth reporting year, where applicable transitional reliefs are used. This was subsequently extended by an additional two years, meaning CREs may defer disclosure of Scope 3 GHG emissions until their fifth reporting year and comparative Scope 3 information until its sixth reporting year.

Under the mandatory climate reporting “climate standards”, the XRB recognises globally accepted standards, such as the GHG Protocol Corporate Accounting and Reporting Standard and ISO 14064-1, for GHG emissions measurement and reporting. The XRB does not mandate a specific GHG emissions measurement approach, but requires CREs to disclose the standards they use. The XRB has determined, through consultation and analysis, that different measurement standards can yield comparable results. Therefore, CREs must transparently disclose their chosen standards under the XRB's guidelines.

Mandatory climate reporting

Yes. For accounting periods ending on or after 31 December 2025, Scope 1 and Scope 2 GHG emissions disclosures must be assured. Following the CR Amendments, CREs may continue to rely on transitional relief from mandatory assurance of Scope 3 emissions disclosures for accounting periods ending before 31 December 2027, meaning Scope 3 assurance becomes mandatory for periods ending on or after that date.

The assurance practitioner must comply with applicable standards when carrying out the assurance engagement (i.e., the Standard on Assurance Engagements 1 issued by the XRB on 3 August 2023). The assurance engagement can also cover other parts of the climate-related disclosure, or the whole statement. 

The assurance report will have to be filed with the climate statements.

NZX Guidance / FMA Disclosure Framework

No assurance required. 

Yes. A number of non-CRE New Zealand entities have voluntarily included TCFD-based climate-related disclosures in their annual reporting. This voluntary inclusion has increased since 2019 when the New Zealand Government endorsed the TCFD Recommendations.

In respect of the NZX Guidance, it is also relatively common for NZX-listed issuers to include ESG disclosures in their annual reports. This disclosure is increasingly requested by investors.

It is also common in New Zealand for integrated financial products to be issued with ESG-related disclosures.

In July 2024, the Centre for Sustainable Finance: Toitū Tahua (CSF), an industry body, prepared a recommendations report for developing a sustainable finance taxonomy for New Zealand.  CSF had been tasked by the New Zealand Government to convene an Independent Technical Advisory Group to prepare and publish non-binding advice on the design of a taxonomy and to provide its recommendations to the Minister for Climate Change. 

Since July 2024, development of New Zealand’s sustainable finance taxonomy has progressed with ongoing work focused on key sectors. A public consultation on the taxonomy was conducted in mid-2025, focusing on defining clear criteria for sustainable activities, with an initial focus on the forestry and agricultural sectors. The taxonomy is expected to be finalised in December 2026.

The XRB has stated that it is committed to paying close attention to the ISSB’s work, including IFRS S1 and IFRS S2. The XRB has acknowledged the need to enable New Zealand entities to report in a globally consistent manner and issued a request for information in May 2025 on the costs and benefits of aligning New Zealand climate reporting with international standards. A post-implementation review commenced in December 2025, during which the XRB considered aligning climate reporting standards with international standards if they meet user needs and the objective of the New Zealand Climate Standards. Under the proposed roadmap, an IFRS S2-aligned climate reporting standard would take effect and replace the current TCFD-aligned requirements from 2033, with early adoption permitted.

CREs have now completed their first and second mandatory climate statements, marking significant milestones in New Zealand’s climate-related disclosure regime. The FMA and XRB continue to play key roles, with the focus having shifted from preparation support to monitoring and enforcement.

In May 2026, the FMA released its second Insights Report on Climate Disclosures, providing feedback from its reviews of climate statements for the second year of reporting. It noted encouraging improvements across sectors including clearer report structures, improved GHG emissions disclosures and better governance and risk management articulation, while highlighting areas for continued improvement.  

As outlined in section A.2 above, the Government has announced the CR Amendments, which will result in significant changes to the scope of the climate-related disclosure regime and narrow the number of CREs. The FMA has confirmed a “no action” approach for affected entities while amending legislation passes (expected in 2026). The CR Amendments will also soften liability settings for directors of CREs – see section C.4 below for more detail.

The Modern Slavery Bill, which passed its first reading in April 2026, would impose new obligations on businesses operating in New Zealand with annual revenue above NZ$100 million to report annually on their modern slavery risks. A modern slavery statement must include details of the entity’s structure, operations and supply chains, any modern slavery incidents that have occurred, known or anticipated risks of modern slavery, and actions taken to assess, prevent, address, mitigate and remediate such risks. There are also requirements to disclose the number of complaints received, and investigation and remediation measures. Enforcement consequences proposed under the bill include potential personal liability for directors and others involved in producing the disclosures. The Select Committee report-back date is set for 31 August 2026. If enacted, the framework could take effect in early 2027, with the first mandatory statements expected in 2028.

Yes. At the end of 2019, the New Zealand Government set a target of achieving net-zero GHG emissions by 2050 (other than for biogenic methane, for which the target was to reach a 24-47% reduction below 2017 levels by 2050). The biogenic methane target was last updated in December 2025 via an amendment to the Climate Change Response Act, lowering the required reduction levels (to 14-24% below 2017 levels by 2050) and adding a requirement to consider implications for domestic food production.

The Climate Change Response Act 2002 requires the Government to set “emissions budgets” (the total quantity of emissions allowed during an emissions budget period). This aims to keep the Government on track to meet its long-term reduction target. Each emissions budget covers a multi-year period.

The Government has set the first three emissions budgets and published an Emissions Reduction Plan. The Emissions Reduction Plan includes actions relating to system settings for reducing emissions, including approaches for empowering Māori, ensuring an equitable transition plan and working with nature. It also includes plans for reducing emissions in key emitting sectors, including the energy and industry sectors.

In November 2024, the Climate Change Commission recommended updating the 2050 target to reflect evolving scientific understanding, international developments and the inclusion of emissions from international aviation and shipping.  The Climate Change Commission delivered its final advice on the fourth emissions budget (covering 2036 to 2040) in November 2024, which also included recommendations on revising the first three budgets (2022-2035). 

The Government is required to set the fourth emissions budget by 31 December 2027. This deadline was extended by 24 months to give the Climate Change Commission time to update its advice following revisions to the 2050 biogenic methane targets.

Yes, the New Zealand Emissions Trading Scheme (NZ ETS) is a mandatory carbon-trading market that applies to emitters in specified industries (and voluntary for emitters outside the regime).

The NZ ETS helps reduce emissions by doing three main things:

1. requiring emitters to measure and report on their GHG emissions;
2. requiring emitters to surrender one “emissions unit” (known as an NZU) to the Government for every tonne of emissions they emit; and
3. limiting the number of NZUs available to emitters (i.e., that are supplied into the scheme).

The Government sets and reduces the number of NZUs supplied into the scheme over time. This limits the quantity that emitters can emit, in line with New Zealand’s emission reduction targets.

Businesses that participate in the NZ ETS can buy and sell units from each other. The price for NZUs reflects supply and demand in the scheme.

New Zealand does not currently impose (nor are there plans to impose) any carbon taxes or CBAMs.

There is no mandatory requirement to have a transition plan. However, in its climate statement, each CRE is required to include the transition plan aspects of its strategy, including:

1. how its business model and strategy might change to address its climate-related risks and opportunities; and
2. the extent to which the transition plan aspects of its strategy are aligned with its internal capital deployment.

Disclosure of the transition plan aspects of a CRE’s strategy was optional in the first year of reporting and became mandatory from the second year of reporting. 

In December 2024, the XRB published staff guidance documents on transition planning to support CREs that were preparing their second-year climate statements. Chartered Accountants Australia and New Zealand also published information guidance on transition plans in May 2025.

There is no mandatory requirement to set targets. However, in its climate statement, a CRE is required to disclose information on the metrics and targets used to measure and manage climate-related risks and opportunities. The XRB has prepared relevant guidance on this. 

Information on targets must include:

1. the relevant timeframe;
2. any associated interim targets;
3. the base year from which progress is measured;
4. a description of performance against the targets; and
5. specific information for each GHG emission target.

Under the Waste Minimisation Act 2008, there is a mandatory product stewardship scheme in place for tyres, with schemes for five other priority products (including plastic packaging and e-waste) at various stages of consideration.

The Ministry for the Environment has proposed replacing product stewardship with a suite of EPR schemes, which would place additional legal obligations on producers to reduce waste and manage products throughout their life cycle.

The consultation period for this proposal ended in June 2025, and outlined five primary proposals:

1. developing an EPR framework to ensure producers remain responsible for products after consumer use;
2. changing the allocation method of waste levies to local governments and clarifying the use of those funds;
3. clarifying roles and responsibilities of central government and the waste industry;
4. improving tools for compliance, monitoring and enforcement; and
5. enabling efficient and effective measures to manage illegal dumping and other improper waste.

In addition, the Ministry is currently consulting on options to reduce GHG emissions from organic waste, as part of the second Emissions Reduction Plan.

There are no mandatory eco-design standards in New Zealand at present.

No. New Zealand does not currently have mandatory corporate sustainability due diligence requirements comparable to the CSDDD.

However, there are plans for modern slavery reporting obligations (see section A.12 above) that would require in-scope businesses to disclose known or anticipated risks of modern slavery, and any actions taken to assess, prevent, address, mitigate and remediate such risks. Although these are reporting obligations (rather than the more onerous positive due diligence duties initially canvassed in 2022), they nevertheless represent a significant regulatory upgrade and would likely encourage in-scope businesses to enhance their supply chain diligence processes to address modern slavery risks.

The Government has taken several steps to support sustainable finance and investment in New Zealand. Key measures include supporting the development of a sustainable finance taxonomy, the mandatory climate-related disclosure regime for CREs, the NZ ETS and the Government’s Emissions Reduction Plan.

New Zealand’s second Emissions Reduction Plan 2026-2030 shows New Zealand is on track to meet the first two emissions budgets, the 2050 biogenic methane target, and the net zero 2050 target, with emissions meeting net zero as early as 2044.

As outlined in section A.12 above, the Modern Slavery Bill, which passed its first reading in April 2026, would impose new reporting obligations on businesses above a NZ$100 million financial threshold, requiring mandatory modern slavery statements in annual reports and creating potential personal liability for directors and others involved in producing the disclosures.

Whilst the consumer and financial markets regulators (the Commerce Commission and the FMA) have each issued regulatory guidance regarding greenwashing and sustainability-related disclosures, there have been relatively few examples of legal proceedings or regulatory actions regarding greenwashing in New Zealand. However, recent examples include:

1. Z Energy: Proceedings against Z Energy were lodged in the High Court in 2023 by Lawyers for Climate Action New Zealand and Consumer New Zealand for greenwashing. The claimants submitted that Z Energy had made numerous claims, giving the impression that it was attempting to significantly reduce its emissions and mitigate its contribution to the climate crisis, despite being New Zealand’s second largest GHG emitter. The case settled in November 2025 with an apology from Z but no admission of liability.
2. Fonterra: In September 2024, Greenpeace Aotearoa issued proceedings against Fonterra regarding the labelling of Anchor butter as “100% grass-fed”.  Fonterra removed the labelling and undertook not to use the label on packaging in the future in April 2026 but made no admission on whether the packaging was misleading.

In addition, the Advertising Standards Authority (ASA), a self-regulatory body funded by the advertising and media industries, has issued a number of decisions including findings of “greenwashing”. For example, Christchurch Airport chose to remove the words “climate positive” in relevant advertisements following a complaint made to the ASA regarding greenwashing in January 2024.

Beyond greenwashing, the Supreme Court’s 2024 decision in Smith v Fonterra Co-operative Group Ltd marks one of the first times in the common law world that a court has recognised an arguable possibility that tort law can be used to challenge the GHG emissions of private entities. The Supreme Court overturned the Court of Appeal’s decision to strike out all claims against seven corporate defendants who are major emitters in New Zealand, and allowed Mr Smith’s claims in negligence, public nuisance, and a novel “climate system damage” tort to proceed to trial.  However, see section C.4 below for the Government’s proposed response to this case.

No, but the general prohibitions under the FMCA and Fair Trading Act (FTA) will apply (see section C.3 below). The Commerce Commission has issued general guidance on environmental claims.

There are no specific prohibitions against “greenwashing”. However, New Zealand’s consumer protection and financial services legislation (the FTA and the FMCA) each contain restrictions on “unsubstantiated representations” (being representations that are not supported by reasonable grounds at the time they were made), which are likely to be the primary basis for any allegation of greenwashing.

The regulators currently have an active focus on greenwashing and sustainability-related claims in both consumer and financial markets contexts, signalled by the FMA’s 2026 updated sustainability-related disclosure guidance.

More generally, New Zealand is likely to introduce a new statutory class actions regime (following recommendations by the Law Commission in 2022), which is likely to increase the risk of greenwashing or sustainability-related claims where large numbers of consumers are affected.

In addition, the Fair Trading Amendment Bill, introduced in May 2026, proposes significant reforms including shifting most FTA breaches from criminal to civil enforcement and raising maximum penalties. These changes would strengthen the enforcement framework applicable to greenwashing and sustainability-related claims under the FTA. Penalties for body corporates will increase from NZ$600,000 to the greater of NZ$5 million; or three times the value of the commercial gain made or loss avoided; or the value of the consideration for the transactions that constituted the contravention.

Under the current climate-related disclosure regime, directors are deemed liable for breaches of certain disclosure obligations by a CRE. The liability settings for directors of CREs are expected to be softened upon enactment of the CR Amendments (outlined in section A.2 above), whereby directors will no longer be deemed liable solely by virtue of a CRE's breach of the climate reporting rules. In addition, the Government’s announcement stated directors and CREs will not have to show the same level of evidence for climate disclosures as they do for financial disclosures (noting that "climate reporting involves future-focused and uncertain information, unlike financial reporting, which draws on historical information").

Beyond greenwashing and sustainability-related disclosures, the Supreme Court’s decision in Smith v Fonterra Co-operative Group Ltd saw one of the first times in the common law world that a court has recognised an arguable possibility that tort law can be used to challenge the GHG emissions of private entities. However, in May 2026, the Government announced plans to legislate to prevent findings of tortious liability for climate change damage caused by GHG emissions. The Climate Change Response (Tort Liability) Amendment Bill was introduced under urgency to Parliament, where it received its first reading in July 2026.