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RIAA urges the Finance and Expenditure Committee to reject the proposed changes to the CRD regime and encourage Government to adopt measured, proportionate amendments that maintain New Zealand’s leadership in climate related disclosure, uphold market integrity, and attract global capital. The regime’s purpose, investor needs, and international credibility should guide final decisions.
The proposed changes to the Financial Markets Conduct Amendment Bill –Amendment Paper No 446: Climate Related Disclosure Amendments – would markedly narrow the regime by raising listed issuer thresholds to NZD 1 billion, removing managed investment scheme (MIS) managers from scope, and softening director liability settings. These changes go beyond the scope signalled in the MBIE consultation and risk undermining investor confidence, capital allocation quality, capital inflows to New Zealand and New Zealand’s international standing.
New Zealand has positioned itself as a leader in climate-related disclosure. Diluting the regime at a time when climate change is moving up the considerations of global investors would move the country from leadership to laggard status, making it harder to attract long-term investment and undermining the credibility of our financial system. Policy certainty and stability are essential. Implementation challenges should be addressed by working collaboratively with industry, not by dismantling the framework.
A regulated mandatory climate reporting disclosure regime provides a consistent baseline expectation of information that should be provided to the market and stakeholders. This allows for increased transparency and comparability. In addition, clear expectations can reduce cost and resourcing burden and mitigate risk.
RIAA also refers to and supports the submissions from the Principles for Responsible Investment (PRI) and the Investor Group on Climate Change (IGCC).
Summary of concerns
- The proposed amendments substantially reduce the information available to investors and others to understand systemic climate risk, do not align with Australian reporting requirements and negatively impact informed investment decision making by consumers.
- A dramatic rollback risks moving New Zealand from climate‑disclosure leadership to laggard, undermining transparency and credibility in the eyes of global investors
- Policy stability matters. Weakening the regime sends the wrong signal to domestic and international investors, making it harder to attract long-term investment. Implementation challenges should be solved in partnership with industry – not by diminishing the framework.
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