The Financial Markets Authority (FMA) announced it will extend the no action relief for climate reporting entities (CRE) from climate reporting obligations under Part 7A of the Financial Markets Conduct Act 2013 (FMCA) for the first five 2026/2027 reporting periods.
The Financial Markets Conduct Amendment Bill 2025 (FMC Amendment Bill) proposed changes that would relieve certain entities from climate reporting obligations under the FMCA, however the FMC Amendment Bill failed to pass before the last day of Parliament’s term.
The FMA’s announcement to extend no action relief is available here.
Who needs to read it? Why?
The FMA has extended its no action relief for the following CREs which the Government proposed to remove from the climate related disclosure (CRD) regime in 2025:
- listed issuers with a market capitalisation below NZD$1 billion;
- managed investment scheme (MIS) managers; and
- health and life insurers.
The affected CREs should review their 2026/2027 reporting period start dates, balance dates and expected due dates for lodgement to assess whether they can rely on the FMA’s extended ‘no action relief’.
What does it cover?
The FMA issued its original ‘no action relief’ on 28 October 2025 for the 2025/2026 reporting period to assist affected CREs with lodgement obligations that would have occurred before the FMC Amendment Bill was expected to pass. ‘No action relief’ means that the FMA will not take any action against a person for a breach of the CRD obligations under Part 7A of the FMCA, but it does not preclude third parties from taking an action against a person breaching the CRD obligations under Part 7A of the FMCA.
Since the FMC Amendment Bill was not passed before Parliament rose ahead of the 2026 general election, the FMA has extended its existing no action relief for the first five 2026/2027 reporting periods with balance dates of 31 March 2027 up to and including 31 January 2028. The ‘no action relief’ will stop applying to reporting periods which have a balance date of 31 March 2028 and later.
Our view
We support the FMA providing certainty for affected CREs for the first five 2026/2027 reporting periods and reducing unnecessary compliance costs. In our view, clarity for affected CREs on their future CRD reporting obligations is essential, and a law change is necessary to achieve that outcome. Until the next Government is formed, the FMA and affected CREs have no clear direction on the future of their CRD reporting obligations and whether the FMC Amendment Bill will be passed by the newly formed Government. The FMA has indicated that if the newly formed Government does not support the FMC Amendment Bill, affected CREs will need to resume reporting. We consider it important that affected CREs have certainty as soon as possible, given they are currently uncertain about whether their CRD obligations will continue to apply.
What next?
If you have any questions in relation to the FMA’s extended no action relief or are considering how the no action relief may affect your climate reporting obligations, please contact one of our experts.
This article was co-authored by John Anayi and Leanne Chew, Solicitors in our Financial Services team.
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