Gearing up for action: Beyond mandatory climate disclosures

Amendments to New Zealand’s mandatory climate-related disclosures regime saw the reduction of director liabilities and substantiation requirements, and raised reporting thresholds. The changes, announced in October 2025, resulted in a 54% reduction in the number of mandated Climate Reporting Entities (CREs), from 164 to 76, with 66 listed companies and 22 MIS managers exiting the regime.

When the amendments to the regime were first announced, a common refrain echoed by many entities exiting the regime was: “Does that mean we’re off the hook?” The removal of mandated disclosure requirements does not reduce investor and other stakeholder expectations around continuing disclosure on the governance of material climate and nature-related risk. Decisions to stop climate reporting; to continue to voluntarily report; or to provide some information to meet investor or stakeholder demand, also carry risk that needs to be managed.

To support entities transitioning out of the mandatory climate disclosures regime, Deloitte, in collaboration with the Climate Leaders Coalition and Sustainable Business Council, ran a series of workshops designed to aid exiting CREs navigate the options for voluntary climate reporting. Consideration was given to regulator expectations, legal obligations, evolving international standards, and how to navigate political uncertainty. The workshop series culminated with a session on nature-related risks and dependencies; and the convergence of climate, nature and capital allocation in decision-making.

This report summarises the key outputs of the workshops, notably: legal and regulatory considerations for entities to keep front of mind as they step into the voluntary disclosures space; considerations relating to the current and future state of standards in view of ongoing harmonisation; and considerations on how to approach integrating nature risk within transition planning.

The workshop series brought together a diverse group of participants, representing a range of roles, disciplines, and organisational contexts from across a wide variety of sectors. Attendees included corporate sustainability practitioners, regulatory and risk managers, consultants, directors, and finance teams.