Climate change creates financial risks and opportunities to a large number of businesses. Currently, these financial impacts are not being adequately considered, valued and reported on within financial markets. This may create further risk for investors, shareholders and pension holders.   The Government is seeking your feedback on a proposal that would require financial firms and listed companies to understand and report on how climate change affects them will impact their business and investments, in a consistent way. The aim is to help market players make more informed decisions. Please fill in the form below, then click Continue to review your submission. At any time you may click Save and Exit so that you can return later.

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Submitter type
What type of organisation do you represent?
Chapter 1
Q.1 Is the TCFD reporting framework the most appropriate framework for New Zealand?
Q.2 Do you agree with the conclusions we have drawn at the end of chapter 1?
Chapter 2
Chapter 3
Chapter 4
Chapter 5
Q.11 Do you favour the status quo or new mandatory disclosures?
Q.12 If a mandatory approach is adopted, do you agree with the Productivity Commission that a mandatory (comply-or-explain) principles-based disclosure system should be adopted?
Q.13 If the status quo is retained, how can government and investors be confident that risks would be routinely considered in business and investment decisions?
Q.14 Do you consider the TCFD framework to be best practice in relation to climate-related financial disclosures?
Q.15 What are your views about whether the TCFD’s recommended disclosures will provide useful information to institutional investors and other users?
Q.16 Do you think the proposed disclosure system will encourage disclosing entities to make better business decisions?
Q.17 Is the definition of materiality in the IASB Conceptual Framework for Financial Reporting appropriate for this purpose?
Q.18 What comments do you have on our proposal that non-disclosure would only be allowable on the basis of the entity’s analysed and reported conclusion that they see themselves as not being materially affected by climate change, with an explanation as to why?
Q.19 What are your views about providing a transition period where incomplete disclosures would be permissible?
Q.20 If there is to be a transition period, what are your views on it being for one financial year?
Q.21 Should all of the following classes of entity be subject to mandatory (comply-or-explain) climate-related financial disclosures: listed issuers, registered banks, licensed insurers, asset owners and asset managers? (check all that you believe should fall in scope)
Q.22 Should any other classes of entity be required to disclose?
Q.23 Should there be an exemption for smaller entities?
Q.24 If there were to be an exemption: (a) What criterion or criteria should be used: annual revenue, total assets, a combination of the two, or some other measure or measures? (b) Which dollar amount or amounts would be appropriate? (c) Should there be a requirement to adjust for inflation from time-to-time?
Q.25 What are your views about our proposal to have a stand-alone climate-related financial disclosure report within the entity’s annual report?
Q.26 What are your views about providing for disclosing entities to include cross-references or mappings within that report to assist users to find relevant information?
Q.27 What are your views about requiring explanations for non-compliance to be included in the annual report?
Q.28 Should there be mandatory assurance in relation to climate-related financial disclosures?
Q.29 Which classes of information should be subject to assurance if it were to be mandatory?
Q.30 Do you consider that assurance should be required in relation to GHG emissions disclosures?
Q.31 Is limited assurance the only practicable approach in relation to TCFD disclosures, or is reasonable assurance also feasible?
Q.32 If we do not introduce mandatory assurance when a disclosure system comes into effect, should it be reconsidered in the future?
Q.33 What comments do you have on the proposal to bring the disclosure system into force for financial years commencing six months on or after the date that the regulation is introduced?
Q.34 Do you consider that smaller entities should be provided with a longer transition if there were to be no exemption for them? If so, how long should that additional period be?
Q.35 Do you have any views about the legislative means for implementing new mandatory (comply-or-explain) disclosure requirements?
Q.36 Do you consider that there is a role for government in relation to guidance, education, monitoring and reporting?
Q.37 Are there other activities that a government agency could usefully carry out?
Q.38 Which government agency or agencies will be best able to carry out these functions?
Q.39 What would you need to assist you with a full set of TCFD disclosures?
Q.40 What information do you have about the cost implications relating to these proposals?
Q.41 What information do you have about costs for specific types of reporting entities?
Q.42 Do you have any other comments?

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