Submission to XRB: Current disclosure timeframes position Aotearoa New Zealand as a destination for international capital
29 September 2025
IGCC responded to the External Reporting Board (XRB) proposals to delay by a further two years disclosure and assurance of Scope 3 greenhouse gas (GHG) emissions and disclosure of anticipated financial impacts (AFI).
Investors are increasingly looking for markets where climate-related financial risks and opportunities are effectively managed. Markets with robust mandatory climate reporting rules are well place to attract climate-aware global capital.
IGCC has recommended:
- No delay to Scope 3 and AFI disclosures. Investors need this information for investment decision-making and stewardship. Retaining the existing disclosure timeframes is in the interests of Aotearoa New Zealand’s investment credibility.
- A minor pause on the Scope 3 assurance requirements. This would allow reporting entities to improve internal systems and processes. It would also allow industry to address unintended inefficiencies and duplication faced by MIS managers in relation to the assurance of their Scope 3 financed emissions disclosures.
IGCC also observes that the lack of clarity about the outcomes of the Capital Market Reforms as consulted by the Ministry for Business, Innovation and Employment is creating uncertainty for CREs in terms of coverage and the operation of CRD going forward. To set the climate reporting regime on solid footing and create certainty for investors, the IGCC calls for a prompt resolution to the current deliberations.
In a world of finite and increasingly climate-aware capital, Aotearoa New Zealand has the opportunity to maintain its reputation as a market with the right settings in place to signal to investors that climate-related risks and opportunities are appropriately managed.
Read the full submission.