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Submission

September 24, 2025

XRB – Proposed 2025 amendments to climate and assurance atandards

Download the full submission here

RIAA has submitted to XRB that it does not support a further extension to disclosure relief for scope 3 GHG emissions or anticipated financial impacts, but accepted that a short extension of one year to assurance relief for scope 3 GHG emissions would be appropriate.

Disclosure of climate risk will be essential to achieving more accurate risk management and valuations. This should lead to faster, meaningful decarbonisation efforts as well as ensure Aotearoa New Zealand remains an attractive destination for global capital.

However, RIAA notes that, while the regulated disclosure produced by the CRD regime is important, this is not the only purpose of the regime. In preparing the required information under CRD, climate-reporting entities (CREs) will be able to better assess climate risk, upskill their workforce, and build business readiness. Through this process, the quality of climate risk assessment, mitigation and resilience will increase across the economy.

As such, the CRD regime functions as a vital lever within the New Zealand policy infrastructure to enhance not just information in the market but the quality of companies and businesses which are able to better operate in the current environment. In addition, the ability to attract global capital relies on certain information being provided; a degree of international interoperability and international alignment where major global economies have mandated similar disclosure.

Allowing a lower standard of climate risk disclosure domestically will undermine the ability of New Zealand to both attract capital to its shores and for its businesses to be able to compete effectively overseas. This would have a direct impact on the New Zealand Government’s priorities relating to attracting capital, including:  

  • the importance of ‘promoting global trade and investment’ as one of five pillars critical to lifting economic growth and improving New Zealanders’ standard of living;
  • initiatives relating to foreign direct investment; 
  • establishing Invest NZ and resourcing it under the 2025 Budget to attract investment to New Zealand; and  
  • the Going For Growth agenda focused on the actions the Government is taking to realise the potential of the New Zealand economy;  

 

RIAA has relied on and refer to the following submissions:

 

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