Note: The following statement of reasons should be read in conjunction with the statement(s) of reasons appended to the:

• Financial Markets Conduct (Climate-related Disclosures—Assurance Engagement) Exemption Amendment Notice 2026

This notice comes into force on 28 April 2025 and is revoked on 30 April 2026.

This notice concerns disclosure requirements for climate statements, or group climate statements, that climate reporting entities are required to prepare under Part 7A of the Financial Markets Conduct Act 2013 (the Act). Under section 461ZH(1) of the Act, climate reporting entities must ensure that the statements are, to the extent that the statements are required to disclose greenhouse gas emissions, the subject of an assurance engagement. This notice exempts climate reporting entities from that assurance duty in relation to the disclosure of information about scope 3 greenhouse gas emissions, which are a category of emissions identified and defined in Aotearoa New Zealand Climate Standard 1—Climate-related Disclosures.

The exemption applies only to accounting periods ending before 31 December 2025 and is subject to the condition that certain information (outlined in clause 7(2)) be given to the Registrar no later than 4 months after the end of the accounting period to which the exemption relates.

The Financial Markets Authority (the FMA), after satisfying itself as to the matters set out in section 557 of the Act, considers it appropriate to grant the exemption because—

• the exemption promotes confidence in financial markets by complementing the temporary relief that the External Reporting Board granted in November 2024, in particular the inclusion of adoption provision 8 in Aotearoa New Zealand Climate Standard 2—Adoption of Aotearoa New Zealand Climate Standards (NZ CS 2) to provide an optional delay of 1 year in assurance of scope 3 greenhouse gas emissions disclosures; and

• the exemption encourages climate reporting entities to disclose all or part of their scope 3 greenhouse gas emissions in year 2 of their climate reporting, which promotes informed participation in financial markets by enabling information about scope 3 greenhouse gas emissions to be available; and

• the exemption promotes fairness in year 2 of climate reporting between those climate reporting entities who use adoption provision 4 in NZ CS 2 to not disclose any scope 3 greenhouse gas emissions (thereby avoiding the assurance requirement) and those who choose not to rely wholly or in part on adoption provision 4 in NZ CS 2 and disclose all or part of their scope 3 greenhouse gas emissions, by not requiring those disclosures to be assured; and

• the exemption is not broader than reasonably necessary to address the matters that gave rise to it because—

  • the relief applies only to assurance of scope 3 greenhouse gas emissions disclosures (and not the other categories of greenhouse gas emissions, specifically, scope 1 and scope 2); and

  • the relief only applies for 1 reporting period to provide flexibility for those climate reporting entities and their assurance providers who have been facing challenges or complexities in obtaining sufficiently reliable information to support assurance of scope 3 greenhouse gas emissions disclosures.

Note: The preceding statement of reasons should be read in conjunction with the statement(s) of reasons appended to the:

• Financial Markets Conduct (Climate-related Disclosures—Assurance Engagement) Exemption Amendment Notice 2026