Every six years, New Zealand undertakes a comprehensive assessment of the climate risks it faces. Through the National Climate Change Risk Assessment (NCCRA), the Climate Change Commission identifies the most significant climate-related risks and opportunities arising from natural hazards, alongside the uncertainties and policy gaps that could undermine the country’s ability to adapt.

The first NCCRA was published in 2020. The Climate Change Commission released its second NCCRA on 7 May 2026 (2026 NCCRA). Its findings are clear: New Zealand remains insufficiently prepared to withstand and respond to the escalating impacts of climate change and extreme weather events.

The NCCRA is a central pillar of New Zealand’s climate adaptation framework. Amendments to the Climate Change Response Act 2002 (CCRA) in 2019 established two key statutory mechanisms to build resilience:

• the NCCRA, which identifies and prioritises climate risks; and 

• the National Adaptation Plan (NAP), first released in 2022, which sets out the government’s responses to those risks.

Each of these documents must be updated every six years, with progress reports delivered every two years on the NAP. Together, these tools were designed to ensure that climate risks are not only identified but actively addressed.

Further detail on New Zealand’s climate change and adaptation framework is available in our previous articles. 

Below, we outline the ten most significant risks identified in the 2026 NCCRA, and the questions they raise about New Zealand’s readiness to adapt.

The ten most significant risks requiring national attention

The Climate Change Commission has identified ten priority risk areas requiring coordinated national action. These were assessed based on severity, cascading and indirect impacts, and readiness of existing policy and institutional responses. For each risk, policy readiness was evaluated on a spectrum ranging from “no significant gaps” to “insufficient”, explicitly identifying where legislative, funding, and delivery gaps persist.

1. Water infrastructure: Drinking water, wastewater, and stormwater systems are already under significant strain, with climate change threatening every component of this infrastructure. While strengthening resilience would reduce a wide range of climate risks, responsibility largely sits with local authorities and lacks national coordination. Reforms of water infrastructure management are underway and present an important opportunity to embed climate resilience into future system design and governance.

2. Buildings: Climate hazards threaten the performance and integrity of buildings, and current frameworks (including the Building Act 2004) do not adequately account for these risks. Continued development in high-risk areas may lock in future exposure, with disproportionate impacts on vulnerable households and, in some cases, the need for relocation.

3. Transportation networks: Transport networks are increasingly exposed to flooding and disruption, affecting reliability, emergency response, and economic activity. Although the current risk is moderate, investment decisions over the next six years will be critical to avoid embedding long-term vulnerability.

4. Social and community wellbeing: Climate change is increasing pressure on mental health, social cohesion, and community stability, particularly where displacement or relocation is required. National readiness is limited, with no comprehensive framework or legislation for adaptation or managed retreat.

5. Emergency management: Emergency management systems are under growing pressure from more frequent and severe climate events. Reviews of recent extreme weather events (Auckland Anniversary Floods and Cyclone Gabrielle) have identified capability gaps. Despite proposed reforms to strengthen emergency responses, the system currently lacks the capacity to manage complex, large-scale events effectively.

6. Risks in the Māori World Ngā mea hirahira o te ao Māori: Climate change compounds existing structural, cultural, and economic challenges for whānau, hapū, and iwi. Impacts extend beyond physical harm to affect cultural identity, taonga, and intergenerational wellbeing, with limited recognition of decision-making rights constraining adaptation.

7. Ecosystems and biodiversity: Climate change intensifies existing pressures on ecosystems, including land degradation and invasive species. Some ecosystems may be pushed beyond recovery, with significant environmental, economic, and cultural consequences. Policy responses remain fragmented and under-resourced.

8. Forestry: Forests face increasing risks from extreme weather, pests, and fire. As a key sector for both the economy and emissions reduction, damage reduces carbon sequestration and increases downstream risks. Long growth cycles mean current planting decisions must account for future climate conditions.

9. Government funding: Funding remains the critical determinant of effective adaptation. Climate change is increasing pressure on public finances through rising costs of disaster response, infrastructure repair, health and welfare services, and long-term adaptation. Limited investment in risk reduction has resulted in high and unpredictable post-event costs, which are difficult to budget for and likely to escalate as climate events intensify.

10.  Decision-making and delivery: New Zealand’s ability to plan and act collectively is under significant strain, and this is identified as a priority risk requiring urgent action. Fragmented governance and contested decision making continue to hinder effective adaptation. There is no legislative framework for managed retreat, no national approach to displacement or relocation, and limited clarity on long-term funding decisions. As a result, local authorities, communities, and infrastructure providers face high-stakes decisions without sufficient national direction. As climate impacts intensify, delayed or poorly coordinated decisions risk entrenching long term vulnerability.

Is there already a framework to address the 2026 NCCRA risks?

The risks identified in the 2026 NCCRA point to a core issue: a lack of clear direction for action, compounded by insufficient and uncertain funding to implement it. These risks closely align with the priority actions identified in the National Adaptation Framework (NAF) in 2025, particularly in relation to decision-making capacity, funding, and infrastructure resilience.

As outlined in our earlier alert, the NAF is a non-statutory policy framework that sets the Government’s long-term direction for climate change adaptation and in support of the NAP. It is structured around four key pillars: risk and response, information sharing, roles and responsibilities, and investment in risk reduction and cost-sharing (both pre- and post-event).

While the NAF does not impose binding legal obligations, it identifies targeted actions to translate priorities into implementation. These include clarifying the roles and responsibilities of councils, investing in emergency management and risk reduction, establishing funding mechanisms, and developing tools to support recovery decisions following major weather events.

This alignment between the NAF and the 2026 NCCRA indicates that the necessary actions are well understood, but that implementation has not kept pace.

Some progress has been made. For example, the National Direction on Natural Hazards came into force on 15 January 2026, investment in resilience has been directed through the Regional Infrastructure Fund, and work is underway on the new National Flood Map. However, implementation of the NAF remains in the early stages. In April 2026, the Government signalled proposed amendments to the CCRA to address gaps in adaptation governance, including clearer obligations on councils and greater certainty around planning and funding. The timing of these amendments remains uncertain, and the Minister for Climate Change, Simon Watts, has indicated that decisions on cost-sharing arrangements have been deferred until the next term of government.

What is next? 

The 2026 NCCRA makes clear that climate adaptation in New Zealand continues to be constrained by a lack of national direction and an absence of clear, durable funding arrangements. Further, responding to and implementing NAF actions would assist in addressing these risks.

The risks identified in the 2026 NCCRA will now inform the development of the next NAP, which is due to be released in 2028. In the interim, the next progress report on the 2022 NAP is scheduled for August 2026, which will assess how effectively existing adaptation measures have been implemented. 

While the NAP progress report will provide an important stocktake of current actions, there is currently no statutory mechanism requiring the NAP to be updated or amended in response to its findings. This raises further questions about the pace of adaptation and whether in the interim the NAF will be sufficient to drive the progress needed to ensure readiness. 

We are continuing to closely follow the reforms to the climate adaptation framework, along with the upcoming NAP progress report.

Please reach out to one of our experts if you have any questions or would like more information on climate adaptation and management. 

This article was co-authored by Aimee Harris (Solicitor), in our Environment team.