Climate-related disclosures, New Zealand

Climate-related disclosures in New Zealand: who reports, NZ CS 1 to NZ CS 3, and where energy data fits

Large listed issuers, banks, insurers, credit unions, building societies and investment scheme managers in New Zealand must prepare climate statements under the XRB's Aotearoa New Zealand Climate Standards and lodge them within 4 months of balance date, with scope 2 emissions calculated on the location-based method. Termina turns your electricity and gas bills into that energy data, and your first 50 bills are free.

Termina is an Australian and New Zealand business energy procurement company and energy data platform.

3
Climate standards, NZ CS 1 to NZ CS 3
4
Thematic areas in NZ CS 1
4 months
After balance date to lodge

As at October 2026. Sources: External Reporting Board; Financial Markets Conduct Act 2013.

Who reports

Who is a climate reporting entity in New Zealand?

Large listed issuers, banks, insurers, credit unions, building societies and investment scheme managers, as defined in Part 7A of the Financial Markets Conduct Act 2013. The tests below decide it.

WhoClimate reporting entity if
Listed issuersQuoted equity securities worth more than NZ$60 million, or quoted debt securities with a face value of more than NZ$60 million, tested over the 2 preceding accounting periods. Issuers quoted only on a growth market are excluded
Registered banks, credit unions and building societiesTotal assets of more than NZ$1 billion at each of the 2 preceding balance dates
Licensed insurersTotal assets of more than NZ$1 billion, or annual gross premium revenue of more than NZ$250 million, in each of the 2 preceding periods
Managers of registered schemesTotal assets across the schemes they manage of more than NZ$1 billion at each of the 2 preceding balance dates

Source: Financial Markets Conduct Act 2013, sections 461O to 461S, version as at 1 July 2026.

Thresholds as at October 2026. Changes to these thresholds were proposed in 2025 but are not in the Act as published at 1 July 2026. If you think a change affects you, check the Financial Markets Authority's current guidance.

The standards

What are NZ CS 1, NZ CS 2 and NZ CS 3?

The three Aotearoa New Zealand Climate Standards, issued by the External Reporting Board (XRB) in December 2022 and applying from 1 January 2023. They are secondary legislation, and climate statements must comply with them.

NZ CS 1

NZ CS 1 Climate-related Disclosures

What you disclose: governance, strategy, risk management, and metrics and targets.

NZ CS 2

NZ CS 2 Adoption of Aotearoa New Zealand Climate Standards

A limited set of adoption provisions for your first reporting periods. Amended in November 2024 and November 2025.

NZ CS 3

NZ CS 3 General Requirements for Climate-related Disclosures

The principles and general requirements behind every disclosure, such as how information is presented.

What you disclose

What does NZ CS 1 require you to disclose?

Four thematic areas. Under metrics and targets, gross greenhouse gas emissions must be split into scope 1, scope 2 (using the location-based method) and scope 3, with an emissions intensity figure.

Governance

How your board oversees climate-related risks and opportunities, and management's role in assessing and managing them.

Strategy

Current climate-related impacts, scenario analysis, the risks and opportunities you have identified, and how you plan to transition.

Risk management

How climate-related risks are identified, assessed and managed, and how that fits your overall risk management.

Metrics and targets

Gross scope 1, scope 2 and scope 3 emissions in tonnes CO2e, emissions intensity, the measurement standard you used and the source of your emission factors.

Key dates

When are climate statements due, and what has to be assured?

Within 4 months after your balance date, delivered to the Registrar for lodgement together with the assurance practitioner's report on the greenhouse gas emissions disclosures.

01

From 1 January 2023: standards apply

NZ CS 1 to NZ CS 3 apply from 1 January 2023.

02

Within 4 months of balance date: lodge

Climate statements and the assurance practitioner's report are delivered to the Registrar for lodgement.

03

Greenhouse gas emissions: assured

Since 27 October 2024, the parts of climate statements that disclose greenhouse gas emissions must be the subject of an assurance engagement.

04

Scope 3: extra time

The November 2025 amendment to NZ CS 2 extends the adoption provisions by two years for scope 3 emissions, scope 3 assurance and anticipated financial impacts.

Breaches of the preparation, assurance, record-keeping and lodgement duties can carry pecuniary penalties of up to NZ$1 million for an individual and NZ$5 million in any other case. Source: Financial Markets Conduct Act 2013, sections 461ZH, 461ZI and 461ZK.

Where energy data fits

Where does energy data fit in your climate statements?

In the metrics: electricity is your scope 2, and on-site gas and LPG are part of your scope 1. Termina turns those bills into validated data by ICP, and your first 50 bills are free.

Your energy data

Electricity you buy is scope 2, and NZ CS 1 requires the location-based method. Gas and LPG you burn on site are scope 1. For most entities the activity data sits on energy bills: kWh per ICP, gas per ICP, period by period, across every retailer.

Termina collects those bills and turns them into validated data. Upload your first bills to see the data today. Authorise us once and we update the billing contact with each retailer, so every bill after that comes straight to us. Each bill is re-added against its own totals and structured by ICP, site and period, with the source bill behind every figure.

What Termina doesn't do: write your climate statements or replace your assurance practitioner. We supply the energy data underneath them.

Start

Free to start (your first 50 bills)

Roughly a year of monthly bills across four sites. Enough to see whether your data comes back clean before you commit to anything.

Procurement clients

$0 when we run your procurement

The full platform costs nothing while Termina runs your energy procurement.

Beyond 50 bills

Talk to us about more options

More sites, more bills or a different setup? Speak to Us and we'll work out what fits. Nothing is charged without you agreeing to it first.

See how it works on the free energy data platform, or find any site's number with our ICP lookup guide.

Questions

Climate-related disclosures, answered

What are the Aotearoa New Zealand Climate Standards?

Three standards issued by the External Reporting Board (XRB) in December 2022: NZ CS 1 Climate-related Disclosures, NZ CS 2 Adoption of Aotearoa New Zealand Climate Standards, and NZ CS 3 General Requirements for Climate-related Disclosures. They apply from 1 January 2023 and are secondary legislation.

Who has to prepare climate statements in New Zealand?

Climate reporting entities under Part 7A of the Financial Markets Conduct Act 2013: listed issuers with quoted equity or debt over NZ$60 million, and registered banks, credit unions, building societies, licensed insurers and registered scheme managers over NZ$1 billion in assets (or, for insurers, NZ$250 million in annual gross premium revenue).

When are climate statements due?

Within 4 months after your balance date. The climate statements and the assurance practitioner's report on them are delivered to the Registrar for lodgement.

Do greenhouse gas emissions have to be assured?

Yes. Since 27 October 2024 the parts of climate statements that disclose greenhouse gas emissions must be the subject of an assurance engagement. The November 2025 amendment to NZ CS 2 gives two more years of adoption provisions for scope 3 assurance.

How do you calculate scope 2 emissions under NZ CS 1?

Using the location-based method: electricity used, from your bills, multiplied by an emission factor. You must disclose the measurement standard you used and the source of your emission factors.

Has the climate reporting threshold changed to NZ$1 billion for listed issuers?

Not in the Act as published at 1 July 2026, which still uses NZ$60 million for listed issuers. Changes were proposed in 2025. Check the Financial Markets Authority's current guidance if you think they affect you.

Is Termina carbon accounting software?

No. Termina supplies the validated energy data underneath your climate statements: electricity, gas and LPG use by ICP, site and period, with the source bill behind every figure. You keep your carbon accounting tool and your assurance practitioner.

How much does Termina cost?

It is free to start with your first 50 bills on the platform, and $0 when Termina runs your energy procurement. For more than that, talk to us about more options.

This page is general information, not legal or accounting advice. Check your position with your adviser or assurance practitioner.

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