The External Reporting Board (XRB) released a consultation document proposing amendments to New Zealand’s Climate Standards (NZ CS 2) and Assurance Standards (NZ SAE 1). The proposed changes aim to extend adoption provisions for Scope 3 greenhouse gas (GHG) emissions and anticipated financial impacts (AFIs), providing climate reporting entities (CREs) with additional time to meet complex reporting and assurance requirements. XRB is now seeking submissions on the proposals.
The link to the consultation document is available here and the link to the online survey to submit on the proposed changes is available here.
Who needs to read it? Why?
These proposed amendments are relevant to all CREs who are subject to mandatory climate-related disclosures. CREs need to understand the proposed changes and the submission process. Assurance practitioners responsible for verifying GHG disclosures should also be aware of the proposals and how to provide feedback.
What does it cover?
The XRB is proposing to extend a number of the NZ CS 2 adoption provisions to give entities more time to develop systems, methodologies, and data quality for effective reporting and assurance. Key proposed changes include:
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Extension of Adoption Provision 2: Defers the requirement for disclosure of AFIs by two additional reporting periods.
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Extension of Adoption Provision 4 (AP 4): Defers the requirement to report Scope 3 GHG emissions by two additional reporting periods.
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Extension of Adoption Provision 8 (AP 8): Defers the requirement for assurance over Scope 3 emissions by two additional reporting periods. The XRB notes that CREs will still be able to use AP 8, even if they elect not to use AP 4 – as currently set out in paragraph 26 of NZ CS 2.
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Related extensions: The following two adoption provisions would also be extended for the same period as any extension to AP 4, but only to the extent they relate to scope 3 emissions disclosures –
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Adoption Provision 5: Comparative information; and
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Adoption Provision 7: Trend analysis.
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NZ SAE 1 amendments: Updates to reflect the extended assurance timelines.
These changes aim to ease the transition for CREs facing challenges with Scope 3 reporting and assurance, while still encouraging early adoption. The XRB cites feedback from CREs and assurance practitioners highlighting issues such as:
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Complexity of Scope 3 calculations.
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Lack of sector-specific guidance.
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Data quality and availability concerns.
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High cost and resource demands of assurance.
If the proposed changes are adopted, CREs would have an additional two years before being required to report and assure Scope 3 emissions and AFIs. This would reduce immediate compliance pressure, allow time to improve data systems and methodologies, and help align New Zealand’s standards with international developments.
Our view
We support the XRB’s proposed amendments, which reflect sector-wide feedback on the challenges of Scope 3 reporting and assurance, and AFIs. These changes will help entities build more robust systems and methodologies, ultimately improving the quality and reliability of climate-related disclosures.
What next?
We would encourage all CREs to review the consultation document and make a submission, even if only to support the proposals.
Submissions must be made by 5:00 PM, Wednesday, 24 September 2025, via this survey. The XRB intends to announce its decisions in October 2025, with amendments taking effect for reporting periods beginning on or after 1 January 2025.
If you have any questions in relation to the proposed changes, or submission process, please contact one of our experts.
This article was co-authored by Olivia Maher, a Solicitor from our Financial Services team.
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