New Zealand suppliers: XRB Aotearoa climate standards and NZX requirements.
New Zealand was one of the first countries to introduce mandatory climate-related disclosures. The External Reporting Board (XRB) Aotearoa standards require large listed companies, banks, and insurers to disclose climate risks and opportunities. New Zealand suppliers to these entities will face data requests.
Key regulations in New Zealand
XRB Aotearoa — Climate-related Disclosures (CRD)
New Zealand's Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021 requires large financial market participants to make climate-related disclosures in line with the XRB's Aotearoa New Zealand Climate Standards. Covered entities must disclose Scope 1, 2, and 3 emissions and climate risk assessments.
NZX Listing Requirements
NZX-listed companies are subject to the mandatory CRD regime. Many are voluntarily disclosing supply chain emissions and requesting data from their New Zealand suppliers ahead of formal requirements.
New Zealand Emissions Trading Scheme (NZ ETS)
The NZ ETS puts a price on greenhouse gas emissions. While primarily targeting large emitters, it creates awareness of carbon costs throughout the economy. Suppliers may be asked about their ETS obligations and carbon management practices.
New Zealand Privacy Act & NCSC Cyber Obligations
New Zealand's Privacy Act 2020 requires organisations to notify the Privacy Commissioner and affected individuals of privacy breaches that have caused, or are likely to cause, serious harm. Notification must be made 'as soon as reasonably practicable' — in practice within 72 hours for serious breaches. The Privacy Commissioner is an active enforcer. New Zealand's National Cyber Security Centre (NCSC) coordinates national cybersecurity and operates CERT NZ for public-facing incident response. The NCSC requires operators of nationally significant organisations to report significant cyber incidents. New Zealand has Five Eyes intelligence sharing arrangements. Suppliers processing New Zealand customer data must align incident response to the Privacy Commissioner notification requirements and NCSC reporting obligations.
What this means for you as a supplier
New Zealand suppliers to large listed companies, banks, and insurers will face requests for GHG emissions data and climate risk information. The XRB Aotearoa standards require Scope 3 disclosures, which means your emissions will be included in your customers' mandatory reports.
Key dates
FY 2023
XRB mandatory CRD for large listed companies, banks, and insurers
Ongoing
NZX-listed companies requesting supply chain emissions data
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received a Modern Slavery questionnaire?
ESG Stress Free guides New Zealand suppliers through Modern Slavery Act and ESG reporting requirements.