Register of climate-related disclosures of NZSX-listed companies

Part of the McGuinness Institute’s ClimateChangeNZ project

Register of climate-related disclosures of NZSX-listed companies

The purpose of this page is to create a temporary centralised register where 2023 climate-reporting information under both the External Reporting Board’s (XRB’s) Aotearoa New Zealand Climate Standards (NZ CS) and the Task Force on Climate-related Financial Disclosures (TCFD) recommendations are accessible for the Institute’s research as well as for individuals and organisations that may wish to use this register. For those who are interested, PwC has recently published their fifth instalment in a series of reports that look into how climate-related risks and impacts on the financial statements are disclosed and how auditors considered climate-related impacts in key audit matters (KAMs). The reports focus on the NZX50.

1. The register

The Institute has always advocated for an official register of companies that make climate-related disclosures to be kept on the Companies Office website. From 2024 onwards, the Companies Office will be hosting a central register where climate reporting entities (CREs) can lodge their climate statements, allowing the general public to search and view copies of each lodged statement (see the register). The first climate statements are due to be lodged by 30 April 2024. The Registrar and the Companies Office will be responsible for maintaining this online register and collecting the related fees and levies.

In the meantime, the Institute has provided a list of the FY23 annual reports (and where necesssary, external reports such as climate reports) of NZSX-listed companies (as at 31 December 2023) where information from either climate-reporting framework, NZ CS or TCFD, can be found. This list will focus on all NZSX-listed companies. We will continue with this list until the Companies Office register becomes live in early 2024 and will update this page accordingly. Columns 6 and 9 below identify whether the information is found in the annual report or in a standalone document, alongside the relevant page numbers. The methodology for the information contained within the list can be found in Working Paper 2024/07: Collating climate statements contained in 2023 annual reports of NZSX-listed companies (see below for more information about this working paper).

2. The climate-related disclosure frameworks

To quickly distinguish between the two climate-reporting frameworks, the Institute has labelled NZ CS as (a) and TCFD as (b). Information regarding each climate-reporting framework, as well as links to the frameworks themselves, can be found below.

A. The External Reporting Board: Aotearoa New Zealand Climate Standards (NZ CS 1, 2 and 3)
In December 2022, in response to the Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021, the XRB issued its Aotearoa New Zealand Climate Standards (NZ CS 1, NZ CS 2 and NZ CS 3).

Under these standards, CREs must make climate-related disclosures in their annual reports, by either including their climate statement or linking to the climate statement online. The standards apply to accounting periods starting on or after 1 January 2023. See each of the standards.

Under Sections 461O–461S of the Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021, these entities are defined as CREs:

(a) a listed issuer that—(i) is a large listed issuer; and (ii) is not an excluded listed issuer: (b) a registered bank that is large: (c) a licensed insurer that is large: (d) a credit union that is large: (e) a building society that is large.

There are two types of NZ CS reporters: (i) mandatory reporters (CREs) or (ii) voluntary reporters. The Institute recommends that reporters make clear in their climate statement whether they are a mandatory reporter (CRE) or a voluntary reporter (non-CRE).

B. The Financial Stability Board: Task Force on Climate-related Financial Disclosures (TCFD recommendations)
In 2017, the Recommendations of the Task Force on Climate-related Financial Disclosures report was published ‘to develop voluntary, consistent climate-related financial disclosures that would be useful to investors, lenders, and insurance underwriters in understanding material risks.’ See the final report. For a detailed analysis of TCFD information included in the previous annual reports of NZSX-listed companies, see Working Paper 2022/14 – Reviewing TCFD information in 2017–2021 reports of NZSX-listed companies.

3. Next steps for the Institute

The Institute has recently published Working Paper 2024/07: Collating climate statements contained in 2023 annual reports of NZSX-listed companies, a working paper that aims to capture the number of NZSX-listed companies that are reporting in their FY23 annual reports the XRB’s Aotearoa New Zealand Climate Standards (NZ CS 1, 2 and 3). This quantitative analysis aims to show how NZ CS is being applied by NZSX-listed companies, one year before they become mandatory for those that are defined as CREs. The paper can be found here.

Table 1: Climate-related disclosures in the FY23 annual reports of NZSX-listed companies as at 31 December 2023 (133)

entries per page

Search:

					A. External Reporting Board (XRB)/NZ CS			B. The Financial Stability Board/TCFD
Number	NZSX code	Legal name	Date of financial statements	FY23 PDF	Mentions of NZ CS	No. of pages	Where found	Mentions of TCFD	No. of pages	Where found
[Col:1]	[Col:2]	[Col:3]	[Col:4]	[Col:5]	[Col:6]	[Col:7]	[Col:8]	[Col:9]	[Col:10]	[Col:11]
1	2CC (previously NZA)	2 Cheap Cars Group Limited (previously NZ Automotive Investments Limited)	31 March 2023	See FY23 annual report	No mention	—	—	No mention	—	—
2	ACE	Ascension Capital Limited	31 March 2023	See FY23 annual report	No mention	—	—	No mention	—	—
3	AFC	AFC Group Holdings Limited	31 March 2023	See FY23 annual report	No mention	—	—	No mention	—	—
4	AFI	Australian Foundation Investment Company Limited	30 June 2023	See FY23 annual report	No mention	—	—	No mention	—	—
5	AFT	AFT Pharmaceuticals Limited	31 March 2023	See FY23 annual report	Yes, mentions intent to publish in FY24	—	See pp. 25, 29 See p. 36 for intent to publish	No mention	—	—
6	AGL	Accordant Group Limited	31 March 2023	See FY23 annual report	No mention	—	—	No mention	—	—
7	AIA	Auckland International Airport Limited	30 June 2023	See PDF*	Yes, full disclosure in an external 'Climate Disclosure Report'. The external report is referred to in the annual report but no weblink is provided	12	See pp. 66–67, 73–84, 94, 101, 147	Yes, reports against TCFD in an external 'Climate Disclosure Report'. The external report is referred to in the annual report but no weblink is provided	13	See pp. 66–67, 71–84, 94, 101, 147
8	AIR	Air New Zealand Limited	30 June 2023	See PDF*	Yes, partial disclosure in an external 'Sustainability Report' with intent to publish with full compliance in FY24. The external report is referred to in the annual report but no weblink is provided	16	See pp. 23, 30–55 See p. 94 for intent to publish	Yes, reports against TCFD in an external 'Sustainability Report'. The external report is referred to in the annual report but no weblink is provided	16	See pp. 23, 30–55, 94

Showing 1 to 10 of 135 entries

Notes to Table 1

The list was generated from NZX, which provided the Institute with a list of NZSX-listed companies on 31 December 2023. Trusts and funds have been removed from the list by only including companies with ‘Limited’ in their name.
Annual reports are searched for and found on each NZSX-listed company’s announcements page.
To be counted as a mention, either the entity (‘External Reporting Board’/’XRB’ or ‘Financial Stability Board’/’FSB’) or the specific standards or recommendations (‘NZ CS’ or ‘TCFD’) must be mentioned. For completeness, we also search for ‘climate’ and ‘disclosures’. These eight terms were searched in each annual report.
The table includes implicit mentions of NZ CS. This is where the standards are indirectly mentioned in annual reports (e.g. the ‘XRB’s reporting standards’ or ‘mandatory climate-related disclosure regime’). Where annual reports contain only implicit mentions of NZ CS, they are identified and labelled as non-specific. This is applicable to six annual reports.
The annual reports included in the table relate only to the 2023 financial year. The TCFD/Sustainability reports are given as at the year of publication. For example, a report published in December 2023 is treated as the 2023 TCFD/Sustainability report.
An asterisk refers to where the Institute has combined more than one company document into one searchable PDF. When the Institute combines more than one company document, we place the management commentary first, followed by the climate statement (such as a TCFD report or a sustainability report) and then the financial statements. This lets us search across all documents for each term. In a few cases, company documents are locked and we are unable to combine documents. In this situation, we reference these separately in the normal way. All page numbers used in the table relate to the PDF viewer rather than the page numbers on the document itself.