The External Reporting Board (XRB) has released consultation on proposed amendments to the Aotearoa New Zealand Climate and Assurance Standards, to extend for two further years exemptions from the requirements for climate reporting entities (CREs) to:
-
Report on and obtain assurance of scope 3 greenhouse gas (GHG) emissions
-
Report on anticipated financial impacts (AFIs).
This consultation follows the XRB's approval in November last year of extensions to exemptions from scope 3 GHG reporting and assurance, and reporting on AFIs.
Reporting and assurance of scope 3 GHG emissions
The effect of the proposed amendments to adoption provisions 4 and 8 in NZ CS 2 will be that a CRE relying on these provisions will be exempt from requirements to report on its scope 3 GHG emissions, and to include scope 3 GHG emissions disclosures in its assurance engagement, for a further two years. Adoption provisions 5 (relating to comparatives to scope 3 GHG emissions) and 7 (relating to analysis of trends) would also be extended by the same timeframe.
The XRB's proposals follow consultations on international alignment of climate reporting and follow-up industry engagement, from which XRB report having heard of challenging implementation issues causing undue costs and reducing comparability and that requirements were more complex and burdensome than anticipated. In addition, these extensions will allow for better international alignment of standards.
Anticipated financial impacts
The effect of the proposed amendments to adoption provision 2 in NZ CS 2 is that a CRE relying on the adoption provision will be exempt from the requirement to disclose AFIs of climate-related risks and opportunities for a further two reporting periods, ie until the end of its fourth reporting period.
The XRB's proposal follows recent developments highlighting significant uncertainty internationally about what is expected from AFI disclosures, including from international standards bodies, including the need for the development of additional guidance, support and implementation time.
Next steps
All CREs that will be impacted by these proposed amendments should consider making a submission before the close of the consultation at 5pm Wednesday 24 September 2025.
If you would like assistance with understanding the amending standards, or have any questions about any aspect of the mandatory climate-related disclosures regime, please contact a member of our financial services team.
This article was co-authored by Andrew Suggate (senior associate) and Nicole McAnulty (solicitor).
