New Zealand Financial Markets Authority grants interim no-action relief for climate reporting entities affected by pending regime changes

The New Zealand Financial Markets Authority (FMA) has issued interim “no action” relief for Climate Reporting Entities (CREs) whose mandatory climate reporting obligations are expected to cease once amending legislation is enacted, meaning the FMA will not pursue enforcement for upcoming climate statement lodgements that may fall before the law changes. The no-action approach starts on 1 November 2025 and covers failures by affected CREs to prepare or lodge climate statements, or meet any other obligation, under Part 7A of the Financial Markets Conduct Act 2013 for the 2025/2026 reporting period. CREs with 30 June 2025 balance dates must still lodge climate statements by 31 October 2025. Affected entities do not need to apply for, or notify the FMA of, reliance on the relief, and the FMA noted that no-action confirmations do not prevent third parties from taking legal action; Part 2 fair dealing provisions continue to apply to representations made in any voluntary climate reporting. The pending changes, to be included in the Financial Markets Conduct Amendment Bill, would raise the listed issuer reporting threshold from NZD 60 million to NZD 1 billion for both equity market capitalisation and quoted debt face value, and remove managed investment scheme managers from the climate reporting regime. The Finance and Expenditure Select Committee is due to report back by 30 January 2026, and the FMA said it will monitor progress and revisit the approach if changes are not made by the time affected CREs would need to start preparing for the 2026/2027 reporting period.