The Financial Markets Authority (FMA) – Te Mana Tātai Hokohoko – has published three documents to support Climate Reporting Entities (CREs) in meeting their obligations under the new Climate Related Disclosure (CRD) reporting requirements.

The purpose of climate standards, as set out in the Financial Reporting Act*, are to provide for, or promote, climate-related disclosures, to:

• encourage entities to routinely consider the short, medium, and long-term risks and opportunities that climate change presents for the activities of the entity or the entity’s group

· enable entities to show how they are considering those risks and opportunities

· enable investors and other stakeholders to assess the merits of how entities are considering those risks and opportunities.

By providing investors and other stakeholders with publicly available climate-related disclosures that can be relied on, the market will be able to make more informed decisions around where to allocate capital and contribute to the overall aim of the Aotearoa New Zealand Climate standards framework – ‘supporting the allocation of capital towards activities that are consistent with a transition to a low-emissions, climate-resilient future’.

The full set of documents the FMA has released are:

• Proposed guidance and expectations for keeping proper climate-related disclosure records
• The FMA’s climate-related disclosures monitoring approach and plan for 2023-2026
• The use of third-party providers in climate related disclosures.

The proposed guidance for keeping proper climate-related disclosure records, published for consultation today, will provide practical examples and guidance, for CREs to meet their record keeping requirements under the regime. The regime will require CREs to produce annual climate statements that identify and report on the impact of climate change on their organisations and disclose greenhouse gas emissions. The record keeping guidance for CREs explains how the FMA will apply the law and describes the principles underlying the FMA’s approach.

The proposed guidance is organised along the “four pillars” underpinning the requirements each business must report itself against:

· The role their governance body and senior management play in assessing, managing and overseeing climate risks and opportunities

· How they identify, assess and manage climate-related risks as part of the risk management pillar

· The strategy pillar requires businesses to consider and disclose how climate change is currently impacting them and how it might do so in the future

· Finally, the metrics and targets pillar describes how a business measures and manages its climate-related risks and opportunities, including greenhouse gas emissions.

Jenika Phipps, FMA Manager, Climate Related Disclosure, said: “For climate statements to be relied upon to achieve the purpose of the climate-related disclosures regime they must be supported by proper records. Records support the accuracy and legitimacy of climate statements, including substantiating how the CRD framework has been applied.

“Proper records help Climate Related Entities and their directors demonstrate compliance with their legislative duties and obligations. We also accept that this reporting regime is new, and the market’s ability to manage data sources and systems for collecting and reporting on climate-related information will improve over time.”

The monitoring approach and plan outlines the FMA’s oversight approach for the first three years of the regime. The first year will focus on setting initial compliance expectations, the second year will aim to support development of best practice and the third year will aim to be a steady state of guidance, monitoring and enforcement.

The third-party information sheet provides guidance to CREs that are considering engaging a third-party provider to deliver services in relation to its Climate Statement.

The proposed guidance for keeping proper climate-related disclosure records is open for consultation until 4 August.

Notes

The CRD regime will capture around 200 entities, comprising:

• Large, listed issuers of quoted equity securities or quoted debt securities (over $60 million in market capitalisation or quoted debt, respectively. Issuers listed on growth markets are excluded)
• Registered banks, credit unions and building societies with total assets over $1 billion
• Licensed insurers with total assets over $1 billion or annual gross premium revenue over $250m
• Managers of registered schemes, such as Kiwisaver schemes and investment funds, (other than restricted schemes) with greater than $1 billion in total assets under management.

The CRD legislation amends the Financial Markets Conduct Act 2013 (the FMC Act), the Financial Reporting Act 2013 and the Public Audit Act 2001 and inserts a new Part 7A to the FMC Act. Under the legislation, CREs will be required to:

• prepare an annual climate statement in accordance with the climate standards issued by the External Reporting Board (XRB)
• obtain independent assurance about the part of the climate statement that relates to the disclosure of greenhouse gas emissions
• make the climate statement available to the public
• comply with record-keeping requirements.

*The Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021 amended the Financial Markets Conduct Act 2013 (FMC Act), the Financial Reporting Act 2013, and the Public Audit Act 2001.

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