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.
As at October 2026. Sources: External Reporting Board; Financial Markets Conduct Act 2013.
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.
| Who | Climate reporting entity if |
|---|---|
| Listed issuers | Quoted 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 societies | Total assets of more than NZ$1 billion at each of the 2 preceding balance dates |
| Licensed insurers | Total 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 schemes | Total 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 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.
What you disclose: governance, strategy, risk management, and metrics and targets.
A limited set of adoption provisions for your first reporting periods. Amended in November 2024 and November 2025.
The principles and general requirements behind every disclosure, such as how information is presented.
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.
How your board oversees climate-related risks and opportunities, and management's role in assessing and managing them.
Current climate-related impacts, scenario analysis, the risks and opportunities you have identified, and how you plan to transition.
How climate-related risks are identified, assessed and managed, and how that fits your overall risk management.
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.
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.
NZ CS 1 to NZ CS 3 apply from 1 January 2023.
Climate statements and the assurance practitioner's report are delivered to the Registrar for lodgement.
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 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.
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.
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.
Roughly a year of monthly bills across four sites. Enough to see whether your data comes back clean before you commit to anything.
The full platform costs nothing while Termina runs your energy procurement.
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.
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.
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).
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.
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.
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.
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.
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.
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.
Upload a handful of electricity and gas bills and look at what comes out. Your first 50 bills are free.