The New Zealand Government has announced changes to the country’s Climate-related Disclosures (CRD) regime, aimed at making the rules more targeted and proportionate. These changes are expected to reduce the number of mandatory reporters by more than half, which will ease the administrative burden for some businesses.
At Toitū, we see it as an opportunity for organisations to focus on meaningful climate action rather than compliance. The key proposed changes include:
- Listed issuers of less than $1 billion and managed investment scheme (MIS) managers will no longer be required to report.
- Reduced scope of the regime overall, with the number of reporting entities expected to drop from 164 to 76.
- Directors will no longer be liable for future projections.
Legislation to implement these changes is expected in 2026. For full details, see the Government’s announcement and fact sheet.
Financial Markets Authority provides interim “no action” relief
Following the Government’s announcement, the Financial Markets Authority (FMA) has confirmed that it will take a “no action” approach for entities whose climate reporting obligations are expected to cease once the legislative changes take effect. With this step, the FMA is providing a level of certainty for reporting entities lodging FY25/26 reports after 1 November. However, these businesses should be aware that:
- The ‘no action’ approach applies only to the FMA’s enforcement. It does not prevent third parties from taking action in relation to climate-related statements.
- The position may change. If legislative amendments are not passed before preparations for FY26/27 reporting begin, the FMA may revisit this approach and reporting requirements may resume under the current legislation.
While the national mandate is evolving, global trends show that businesses are increasingly acting voluntarily to address climate risks and opportunities, focusing on real, measurable impact. At Toitū, our vision remains that all New Zealand organisations can achieve a net positive impact on the Earth by 2050. We continue to support organisations of all sizes to measure, manage, and report on their climate-related impact in line with this goal.
For any questions, please contact your Toitū representative who can help you understand what these changes mean for your business, how to navigate what this means for your sustainability strategy and help ensure you don’t lose momentum on climate action.
See the NZ Government announcement here, and the FMA's here.
Please note that this article was originally published on 24 October 2025 and updated on 7 November 2025 to include a reference to the FMA’s “no action” announcement.