Climate-related financial disclosures - submission

The Ministry for the Environment and the Ministry of Business, Innovation and Employment sought feedback on a proposed climate-related financial disclosure regime for organisations.

In our submission, we recognise the importance of climate-related financial disclosure and agree that the recommendations of the Task Force on Climate-related Financial Disclosure (TCFD framework) would be appropriate in New Zealand.

We also:

note that the ‘comply or explain’ approach to implementing the TCFD framework can support good governance
raise questions about how the proposed mandatory requirements will fit with the principles-based nature of the TCFD framework, and how it is intended to be implemented, monitored or enforced
agree that disclosure should apply to listed issuers, banks, general insurers, asset owners and asset managers but we consider that there should be exemptions for some smaller organisations
agree that mandatory assurance obligations should not be imposed at this stage, and
encourage government guidance, education and support to help organisations report effectively.