New Zealand's life and health insurers are no longer required to file mandatory climate statements.
The Financial Markets Authority announced on June 18 that it will take a no-action approach to affected entities while the government's proposed legislative changes work through Parliament - a practical intervention designed to avoid compliance costs accumulating in the gap between policy intent and enacted law.
Commerce and Consumer Affairs Minister Cameron Brewer announced that health and life insurers would be removed from the climate-related disclosures regime on the basis that they are not directly exposed to climate risks such as extreme weather events, making mandatory reporting of limited value. The FSC's chief executive Kirk Hope put the cost of that reporting at $10 million to $15 million a year without clear value for customers - a figure that gives the compliance relief concrete commercial weight.
Nine health and life insurers will be removed from the regime. Combined with 88 businesses removed through earlier decisions, around 67 entities will be required to report once the legislative changes are in place, down from 164 originally. General insurers are not affected and retain their reporting obligations.
"We recognise that many life and health insurers will be impacted by the uncertain timeframe," said FMA general counsel Liam Mason. "This approach will avoid unnecessary compliance costs and promote the development of fair, efficient and transparent financial markets."
The relief applies to life and health insurers with upcoming lodgement dates for the 2025/2026 reporting period. Insurers with 31 March 2026 balance dates onwards are not required to lodge climate statements. Insurers do not need to apply for relief or notify the FMA - it is not a formal exemption, and third parties retain the right to take separate legal action regardless of the FMA's position.
Once the legislative changes are in place, mandatory climate reporting will apply to listed issuers with more than $1 billion in market capitalisation, registered banks, credit unions, building societies and general insurers with assets above $1 billion or revenue over $250 million.
The most important practical note for compliance officers is the FMA's explicit conditionality. If the amending legislation is not passed before the 2026/2027 reporting period, the regulator will revisit its position - and affected entities would be required to resume reporting. No further no-action confirmation should be assumed. The FMA said it would monitor the progress of the legislation accordingly.
Some life and health insurers may choose to continue publishing climate statements voluntarily after the amending legislation is enacted. The FMA noted that the fair dealing provisions in Part 2 of the Financial Markets Conduct Act 2013 will still apply to any representations made in voluntary reporting - meaning insurers who choose to report voluntarily remain subject to the same accuracy and fairness obligations that govern all market communications.
For NZ insurers managing the broader compliance environment, the Reserve Bank prudential levy remains a parallel regulatory cost pressure worth monitoring alongside the CRD changes.
