The Climate Change Commission's Progress Report on the National Adaptation Plan delivers a clear message: New Zealand is not adapting fast enough.

New Zealand's climate adaptation framework has two key components: the National Climate Change Risk Assessment (NCCRA), which identifies and prioritises climate risks, and the National Adaptation Plan (NAP), first released in 2022, which sets out the Government's responses to those risks. The NCCRA and NAP must be updated every six years, and progress reports on the NAP are required every two years.

The Commission's second NAP Progress Report (Report) released on 11 August 2026, reveals that progress has not kept pace with the increasing risk of climate change.

While this finding is not surprising given the deficiencies identified in the second NCCRA, released in May 2026 (outlined in our earlier article), it reinforces the urgency of accelerating New Zealand's response to reduce long-term harm and cost. The Report highlights that New Zealand is still being reactionary and paying for recovery after damage occurs which is becoming increasingly unsustainable as climate risks and impacts continue to grow. It is noted that direct costs to central government and insurers from natural hazards are estimated to be about $4 billion per year, while not accounting for the indirect costs and impacts to people’s physical and mental health, social and community displacement, and lost economic activity from those affected by a hazard event.

The Commission recommends that the next NAP be substantially strengthened, with clearer priorities, stronger implementation measures, and investment and workforce strategies capable of delivering adaptation at the pace and scale required. With the NAP not due to be revised until 2028, the next two years provide a critical window to put necessary systems in place.

Below, we outline the four areas identified in the Report where progress is urgently needed to accelerate New Zealand's climate adaptation.

Closing the adaptation funding gap 

• Funding certainty is critical to accelerating adaptation. The Commission identifies the absence of clear and predictable funding arrangements as the single biggest barrier to progress. Adaptation funding has historically been reactive, fragmented, and largely driven by post-disaster responses rather than long-term planning.
• There is no agreed framework for sharing adaptation costs. Decisions on the Government's proposed "beneficiary pays" approach have been deferred until after the 2026 election, and current funding options remain limited. The Commission recommends that central government clearly define what adaptation activities it will fund and develop new funding mechanisms, including co-funding arrangements, local government funding tools, levies, and private investment models.
• Dedicated funding is also required to support iwi and Māori-led adaptation, particularly as funding through the Māori Climate Platform has been fully allocated. The Commission emphasises that councils, businesses, iwi/Māori, and communities are already making adaptation decisions, making early funding clarity essential to support proactive investment and reduce future climate-related costs.

Clear statutory obligations for adaptation planning

• Recent amendments proposed by the Climate Change Response Amendment Bill, introduced on 15 July 2026, would require councils to prepare adaptation plans for "priority locations” under the proposed Planning Act (outlined in our earlier article). While this is recognised as a good first step, without better tools, guidance, and financing it will not deliver meaningful adaptation outcomes.
• Councils may be required to prepare adaptation plans without corresponding funding arrangements, and there is currently no legislative framework enabling planned relocation outside major public works projects. Further uncertainty remains around how "priority locations" will be identified.
• The Commission highlights the need for clear roles and responsibilities, consistent climate risk assessment methodologies, guidance on evaluating adaptation options, and investment in local government capability. Without this support, there is a risk that new planning requirements create additional compliance burdens without delivering meaningful adaptation outcomes.

Consistently embedding climate change into legislation

• The current legislative framework is fragmented and does not consistently account for climate change risk. The Commission considers that climate change considerations should be embedded across the key laws governing New Zealand's natural and built environments to support coordinated, long-term adaptation outcomes.
• Key legislative gaps are limiting effective adaptation. The proposed Planning Act includes a provision that excludes climate change impacts from the scope of the new regime. This will potentially make it harder for councils to justify adaptation measures such as planned relocation and land-use change. Similarly, the Fast-track Approvals Act 2024 does not require climate risks or adaptation outcomes to be considered, creating a risk that new developments lock in future vulnerability.
• Greater alignment across legislation and planning processes is needed. Councils currently face inconsistent planning timeframes and uncertainty about how local adaptation plans will interact with broader planning frameworks. A more integrated approach would help embed climate resilience into decision-making and ensure adaptation decisions are reflected across wider land-use and infrastructure planning.

A coordinated system for climate risk information

• Climate risk information is currently fragmented and inconsistent. Data is produced by multiple organisations using different methodologies, making it difficult for councils, businesses, and communities to understand and compare risks across New Zealand.
• The Commission recommends establishing a nationally coordinated climate risk information system, underpinned by stronger central government leadership, clear governance, consistent standards, and long-term investment. This would provide a trusted and reliable evidence base for adaptation decisions across the country. This aligns with recent guidance from Minister Watts to councils on their use of climate scenarios in planning. Councils were directed to prioritise adaptive management and to consider a range of climate change scenarios in their planning, rather than defaulting to worst-case projections. Councils are also expected to be transparent about the assumptions underpinning their planning and the additional costs associated with higher-end climate scenarios. This directive marks a shift toward national consistency in the assessment and management of climate risk, however more nationally consistent direction is still required.
• Climate risk information must also be accessible and usable for a wide range of decision-makers. The Commission supports a single national platform for climate risk information, accompanied by tailored guidance for different users. The New Zealand Flood Map, currently in development, provides a practical example of how climate risk information can be centralised and made more accessible to support adaptation decision-making. Better access to consistent information would help decision-makers identify risks, prioritise adaptation measures, and improve resilience over time.

Looking ahead

The Commission's findings reinforce the key weaknesses in New Zealand's current adaptation framework. The four areas outlined above are closely connected – funding certainty underpins adaptation planning, planning relies on high-quality information, and both depend on a legislative framework that consistently accounts for climate change. Rather than waiting until the next NAP review in 2028, the Commission's Report makes it clear that the pace of adaptation needs to accelerate now.

The broader legislative reforms currently underway present a valuable opportunity to establish clearer, more integrated systems for managing climate risk and supporting long-term resilience.

We will continue to monitor developments in New Zealand's climate adaptation framework.

Please contact one of our experts if you have any questions or would like more information on climate adaptation and management.

This article was co-authored by Aimee Harris (Solicitor), in our Environment team.