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New Zealand Financial Markets Authority Extends No Action Relief For Climate Reporting Entities

Date 29/09/2026

The Financial Markets Authority (FMA) – Te Mana Tātai Hokohoko is extending its ‘no action’ approach on climate reporting obligations for affected climate reporting entities.

The Government previously announced changes which would remove listed issuers with market capitalisation below $1 billion, investment scheme managers and health and life insurers from the climate reporting regime through the Financial Markets Conduct Amendment Bill (FMCAB). However, the legislation to confirm these changes did not pass prior to the last day in the House before the upcoming election.

General Counsel, Liam Mason says the FMA recognises many entities are impacted by the uncertainty about their reporting requirements given the amending legislation has not been passed.

To provide certainty to those entities in the interim, the FMA is extending the existing ‘no action’ relief from all Part 7A FMC Act requirements for the first five 2026/2027 reporting periods with balance dates of 31 March 2027 up to and including 31 January 2028.

Reporting period start date 

Balance date 

Due date for lodgement  

Extend no action to provide relief? 

1 April 2026 

31 March 2027 

31 July 2027 

Yes 

1 July 2026 

30 June 2027 

31 October 2027 

Yes 

1 October 2026 

30 September 2027 

31 January 2028 

Yes 

1 January 2027 

31 December 2027 

30 April 2028 

Yes 

1 February 2027 

31 January 2028 

31 May 2028 

Yes 

1 April 2027 

31 March 2028 

31 July 2028 

No 

“We will not have clear direction on the future of this policy until the new Government forms after the November election. This means entities do not know whether they will continue to be required to lodge climate statements and may not know for some months. The ‘no-action’ approach will avoid unnecessary compliance costs and provide some certainty for climate reporting entities in the interim,” says Mr Mason.

If the incoming Government progresses this policy, the FMA will work with affected CREs to provide further relief if required considering the timing of any reform. If the incoming Government’s policy is not to support the passage of the FMCAB, the FMA will work with climate reporting entities to ensure a smooth transition back to reporting, with the understanding that these entities may not be able to provide comparative information for the previous reporting year.

A ‘no action’ approach means that the FMA will not take action against a person for breach of a statutory or regulatory obligation. It is an expression of regulatory intention about how to exercise the FMA’s functions.  An FMA ‘no action’ confirmation does not necessarily preclude third parties from taking legal action in relation to the same conduct or conduct of that kind.    
 

View ‘No action’ relief for climate reporting entities due to be relieved of mandatory reporting

View ‘No action’ relief for life and health insurers due to be relieved of mandatory reporting

Background

The Government previously announced that it intended to raise the reporting threshold for listed issuers from $60 million in market capitalisation to $1 billion and to remove investment scheme managers (including their funds) and health and life insurers from the regime. These changes were intended to be included as part of an Amendment Paper to the Financial Markets Conduct Amendment Bill. The FMA provided ‘no action’ relief to affected CREs for the 2025/2026 reporting periods (with the last reporting period covered having a balance date of 31 December 2026). That no action relief has now been extended.