Navigating the FMA’s 2025 Climate Disclosure Review: Practical Insights for Organisations
In 2025, the Financial Markets Authority (FMA) conducted its first comprehensive review of climate-related disclosures under New Zealand’s mandatory Climate-Related Disclosure (CRD) regime. This review marked a milestone for many large organisations completing their first full reporting cycle under the NZ Climate Standards (NZ CS), which require entities to disclose how climate change impacts their financial position, strategy, and risk management.
The FMA’s review was designed to be both educational and constructive, offering feedback to help organisations enhance the quality and clarity of their climate disclosures over time.
Tonkin + Taylor’s Response: Practical Solutions for Better Climate Reporting
Our climate change specialists at Tonkin + Taylor have developed a set of pragmatic, cost-effective solutions in response to the FMA’s findings.
These are outlined in a concise, downloadable 2-page discussion paper.
We challenge the assumption that high-quality climate disclosures must be expensive. Many organisations already have strong internal capabilities that can be effectively supported by targeted external expertise when needed.
The goal of this paper is to encourage practical, value-driven conversations around climate reporting—making the process both meaningful and financially sustainable.
Key Findings from the FMA’s 2025 Review
The FMA identified a wide range of quality across climate statements, highlighting several areas for improvement:
1. Clarity and Specificity
Many disclosures were overly generic, lacking context-specific detail. For instance, some companies listed broad industry risks without explaining their direct relevance or materiality. Disclosures about climate-related events, such as extreme weather, often failed to link these events to underlying business risks.
2. Completeness and Consistency
Some statements omitted mandatory information, especially when deemed “immaterial” without sufficient justification. The FMA also noted inconsistencies between climate statements and other public documents, such as annual reports.
3. Transition Plans and Financial Impacts
Entities struggled to clearly communicate their transition plans and the financial implications of climate change. Disclosures were often vague, with limited connection between strategy and climate-related financial risks or opportunities.
4. Scenario Analysis
While scenario analysis was commonly included, the FMA found that many organisations did not provide enough detail. Scenarios were often not distinct or challenging enough to test the resilience of business models effectively.
5. GHG Emissions and Assurance
This reporting cycle introduced mandatory independent assurance of greenhouse gas emissions disclosures. The FMA assessed whether assurance was properly conducted and whether the assured information was clearly identified for users.
Join the Conversation
We invite you to explore our discussion paper and share your thoughts. Let’s work together to make climate disclosures more practical, insightful, and cost-effective.
Contact the team
- James Hughes: JHughes@tonkintaylor.co.nz
- Simon Harvey: SHarvey@tonkintaylor.co.nz
- Katherine Cowper-Heays: KCowper-Heays@tonkintaylor.co.nz
