Issuers' mandatory climate reporting threshold to rise to $1bn from $60m
Given the upcoming climate reporting changes, the Financial Markets Authority (FMA) | Te Mana Tātai Hokohoko announced interim relief and a ‘no action’ approach, effective 1 November 2025, for impacted entities expecting their reporting obligations to end upon the legislation’s passage.
In a media release, the FMA said it would no longer expect affected climate reporting entities (CREs) to lodge climate statements in advance of the recently announced changes via the Financial Markets Conduct Amendment Bill.
The FMA noted the potential uncertainty for impacted CREs regarding their obligations under Part 7A of the Financial Markets Conduct Act 2013 (FMC Act), especially their upcoming lodgments for the 2025/26 reporting period, which would likely occur prior to the legislation’s enactment and the relief’s implementation.
“We recognise that many entities preparing for upcoming climate reporting periods will be impacted by the uncertain timeframe in which the amending legislation might be passed, meaning they do not know whether they will be required to lodge climate statements or not,” said Liam Mason, FMA executive director, evaluation and oversight, in the media release.
Under the ‘no action’ approach, for affected climate CREs with upcoming lodgment dates for the 2025/26 reporting period, the FMA clarified that it would not take action for failures to prepare or lodge climate statements or other obligations under Part 7A of the FMC Act.
For CREs with 30 June 2025 balance dates, the FMA pointed out that they still needed to lodge their climate statements by 31 October 2025, given the progress of their lodgment preparations by the time of the government’s 22 October 2025 announcement of the legislative changes.
In the media release, Mason said the ‘no action’ approach would align with the intent of the amendments, address unnecessary compliance costs, and help ensure fairness, efficiency, and transparency in New Zealand’s financial markets amid the legislative changes. Mason added that the FMA would keep monitoring the amending bill’s progress.
“If changes are not made by the time affected CREs are due to begin preparing statements for the 2026/2027 reporting period, we will revisit this ‘no action’ approach,” Mason said. “As reporting obligations will still be in place, affected CREs would need to begin reporting again in the absence of an FMA ‘no action’ in respect of the 2026/2027 reporting period.”
Mason acknowledged that some impacted CREs could elect to keep voluntarily producing climate statements following the enactment of the amending legislation and the reporting threshold adjustments.
“These entities are reminded that the fair dealing provisions in Part 2 of the FMC Act will continue to apply to representations made in voluntary reporting,” Mason said in the FMA’s media release.
The government recently announced changes as part of the Financial Markets Conduct Amendment Bill to raise debt and equity issuers’ mandatory climate reporting threshold to $1bn, from $60m market capitalisation for equity issuers and $60m total face value of quoted debt for debt issuers .
The government also said that the legislative changes would exclude managed investment scheme managers from the climate reporting regime and no longer require them to produce annual climate statements.
The FMA noted that the Finance and Expenditure Select Committee would weigh the planned changes and provide an update by 30 January 2026.
