The Financial Markets Authority (FMA) yesterday published a consultation paper proposing a class exemption for certain climate reporting entities (CREs) incorporated in foreign jurisdictions. The exemption would allow eligible foreign CREs to meet their New Zealand climate reporting obligations by lodging their home jurisdiction’s climate or sustainability reports, provided those reports are broadly equivalent to New Zealand’s requirements.
Submissions close at 5pm on Friday, 24 October 2025.
Links to the consultation paper and the submission form are available here and here.
Who needs to read it? Why?
This consultation matters for any foreign CRE already operating in New Zealand, or thinking about entering the market. It’s especially relevant for overseas banks, licensed insurers, and listed issuers with climate reporting obligations here.
What does it cover?
The consultation proposes a class exemption for foreign CREs that are already subject to comparable climate reporting obligations in their home jurisdictions that are broadly equivalent to the Aotearoa New Zealand Climate Standards (NZ CS), issued by the External Reporting Board. The FMA is seeking feedback on the scope, conditions, and necessity of the exemption, particularly in light of international developments like the ISSB’s IFRS S1 and S2 standards.
Other key aspects of the proposed class exemption include:
- Eligible entities could lodge their home jurisdiction reports on the New Zealand Climate-related Disclosures Register instead of preparing separate NZ CS-compliant climate statements.
- The FMA would rely on the relevant overseas regulators to monitor compliance with the home jurisdiction’s requirements.
- The exemption would be conditional, including requirements to disclose reliance on the exemption and ensure public availability of the foreign report.
- The FMA is welcoming submissions on what overseas jurisdictions should be considered equivalent, and is seeking feedback on how best to assess and recognise those standards.
- The FMA has indicated that climate reporting standards in Australia are likely to be accepted as broadly equivalent to NZ CS, meaning Australian entities will be eligible for the proposed exemption.
The FMA have noted several benefits to such a class exemption. By allowing eligible entities to submit climate or sustainability reports prepared under their home jurisdiction’s standards, provided those standards are broadly equivalent to New Zealand’s, this exemption would significantly reduce the compliance burden and avoid duplication of reporting efforts and costs. Importantly, it also supports international regulatory alignment, recognising the growing convergence of climate reporting standards globally.
Our view
We support the FMA’s intent to promote efficiency, transparency, and international alignment, and encourage affected entities to engage with the consultation process.
What next?
Submissions close at 5pm on Friday, 24 October 2025.
If you have any questions in relation to the proposed exemption or are considering how these changes could affect your business, please contact one of our experts.
Key contacts
Speak with one of our experts.
