The Big Picture - Climate Change

The Big Picture Climate Change

DECEMBER 2025

Contents

Bell Gully

17

At a glance

04

A climate of uncertainty

05

Climate-related developments — a timeline

06

ICJ leads the way in global climate litigation

21

Where to next for New Zealand’s Emissions Trading Scheme?

07

A key case on corporate liability

22

Streamlining the ETS — what the Efficiency and Effectiveness Bill means

08

New Zealand climate litigation

23

Price supply and market governance

10

Farm to forest — curbing conversion

11

On target? Mixed news on emissions budgets

12

Sweeping changes to ClimateRelated Disclosures regime

14

The missing defence that could support sustainability goal-setting

15

The Big Picture Climate Change

Spotlight on greenwashing: a new ESG taxonomy Greenwashing allegations and claims in the courts

The National Adaptation Framework — a new approach to managing natural hazard risk, costs

19

25

The four pillars of the National Adaptation Framework

26

What does the NAF mean for stakeholders?

27

Our practice

28

Our team

29

2

Change to New Zealand’s climate change response and adaptation framework is gathering pace through legislation and court action.

Businesses should monitor policy direction and details expected in 2026.

Bell Gully

The Big Picture Climate Change

3

At a glance The Emissions Trading Scheme

Climate related disclosures

• The central tool to reduce New Zealand’s emissions is undergoing major changes.

• Reporting thresholds lifted to NZ$1 billion for listed issuers while managed investment schemes are excluded from requirements.

• An ‘efficiency and effectiveness’ bill to streamline processes will be introduced next year, while recent legislation decouples the Emissions Trading Scheme (ETS) from New Zealand’s international climate obligations and announces new biogenic methane targets.

• New market governance rules for trading New Zealand Units (NZUs), changes to farm-forest conversion settings and a framework for non-forestry carbon removals add to the changes.

FROM PAGE 7

• Director liability has eased with softer settings, and climate disclosures will require less substantiation.

• We still consider the introduction of a due diligence defence would enhance the regime.

FROM PAGE 13

The National Adaptation Framework

Spotlight on greenwashing

• First national framework sets long-term approach to natural hazard risks.

• Development of a sustainable finance taxonomy is a step forward: reducing ambiguity can reduce the risk of businesses making misleading claims.

• Focus on consistent hazard data, clearer council roles, and cost-sharing before and after an event.

• Managed retreat has been left unresolved, however, and will remain a contentious issue.

FROM PAGE 24

• But greenwashing and climate claims remain litigation risks in New Zealand and overseas.

• We explore key cases and what they tell us.

FROM PAGE 16

Bell Gully

The Big Picture Climate Change

4

A climate of uncertainty As New Zealand heads into an election year, businesses face a dual challenge – navigating climate change policy reforms already in motion while preparing for the possibility of further change.

Change impacting New Zealand’s climate change response framework has gathered pace as 2025 draws to a close.

Significant reform to the scope of the climaterelated disclosures regime, impacting who is in – and who is out – of its reach was announced in October, with future reforms signalled to align with international standards.

New Zealand’s first National Adaptation Framework came out that same month, introducing New Zealand’s first long-term system for managing risks associated with natural hazards that may become more frequent as a result of climate change. But there was no commentary on comprehensive managed retreat, which remains a contentious issue.

Meanwhile, the year has seen the emergence of a range of changes and proposed changes that impact on the New Zealand ETS, including plans to introduce a new Climate Change Response Amendment Bill to focus on efficiency and effectiveness in 2026. With the government having affirmed the ETS will remain the central tool for New Zealand to manage emissions reduction, the topic could take an increasingly prominent role in the policy agenda.

Bell Gully

A key question will be how prominently climate change features in campaigning for the general election in 2026, and who voters task with determining the climate agenda.

Businesses, investors and communities alike will be watching closely: while technical changes may continue regardless, the next election has the potential to be a significant turning point in terms of the direction of climate policy.

In The Big Picture: Climate Change we highlight the key developments from 2025 and what’s to come. Looking ahead, much will depend on the trajectory of climate policy leading up to and following the election next year. For businesses, the challenge will be navigating uncertainty while responding to changes already in motion and preparing for those to come.

The Big Picture Climate Change

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Climate-related developments — a timeline DEC 2024 2024

JAN 2025

MAY 2025

JUN 2025

JUL 2025

SEP 2025

During 2026 Financial Markets Conduct Amendment Bill passage is expected in 2026, which will progress major changes to the climate-related disclosures (CRD) regime

OCT 2025

NOV 2025

DEC 2025

2025

APR 2026

MID 2026

AUG 2026

LATE 2026

2026

Government announced significant changes New Zealand’s second Nationally Determined Contribution (NDC) announced A target of reducing greenhouse gas emissions to 51–55% below 2005 levels by 20352

Consultation opened on the Aotearoa New Zealand Sustainable Finance Taxonomy4

to limit the reach of the climaterelated disclosures (CRD) regime9

FMA consulted market on draft “Ethical Disclosure” Guidance for the marketing of ESG financial products, aim to reduce greenwashing8

He Pou a Rangi

Government releases Second Emissions Reduction Plan (ERP) for 2026-20301

EARLY 2026

Reform of National Policy Statement for Renewable Electricity Generation 2011 (NPS-REG) is proposed3

Climate Change Commission’s annual monitoring report on emissions reductions released,5 Commission notes current policy settings are not enough to deliver against New Zealand’s emissions reductions commitments6

International Court of Justice (ICJ) issues landmark advisory opinion

on States’ climate obligations and the legal consequences of failing to comply with them7

FMA offered a ‘no action’ approach to give interim relief to climatereporting entities (CREs) impacted by the timeframe for enactment of changes to the CRD regime10 Government published New Zealand’s first National Adaptation Framework Changes to New Zealand’s key 2050 emissions targets announced

including revision of the biogenic methane target to a 14-24% reduction against 2017 levels11

Restrictions on conversion of farmland to forestry took effect

XRB’s Sustainability Reporting Board extended adoption provisions deferring adoption of anticipated financial impacts and scope 3 greenhouse gas (GHG) emissions disclosure and assurance requirements for an additional two reporting periods12

Climate Change Response Act reform package announced including proposed changes to ETS operation13

Government released assessment framework for non-forestry carbon removals

Government unveiled Resource Management Act the Natural Environment Bill and the Planning Bill

Climate Change Response (2050 Target and Other Matters) Amendment Bill passed under urgency updating the 2050 biogenic methane target and decoupling the ETS from New Zealand’s NDC under the Paris Agreement

First version of NZ Taxonomy is expected to be published for voluntary market use

Z Energy said it had settled claim alleging it had engaged in greenwashing, with no admission of liability

2027

Introduction of the Climate Change Response (Market Governance and Other Integrity and Efficiency Changes) Amendment Bill is expected

to align ETS secondary market governance with international systems and make various other changes to the ETS

Climate Change Commission set to publish New Zealand’s second National Climate Change Risk Assessment.

Climate Change Response (Efficiency and Effectiveness) Amendment Bill to be introduced proposing changes to operation of the ETS

Climate Change Commission due to publish progress report on National Adaptation Plan 2031 (although noting timeframes for this may change going forward with the government’s proposed Climate Change Response (Market Governance and Other Integrity and Efficiency Changes) Amendment Bill)16

Climate Change Commission set to publish annual emissions reduction progress report15

Climate Change Commission due to publish advice on ETS settings for unit limit and price control for 2027–2031 (although noting timeframes for this may change going forward with the government’s proposed Climate Change Response (Market Governance and Other Integrity and Efficiency Changes) Amendment Bill)14

The first iteration of a National Flood Map is expected in 2027 as part of the NAF

Changes to calculation tables for assessing carbon stored in forests to be in place for use in next mandatory emissions return period, if progressed

Smith v Fonterra trial scheduled

LCANZ v Minister of Climate Change is expected to be heard judicial review proceedings were filed alleging unlawful alteration of the first ERP, and that the second ERP isn’t a lawful plan

following passage of the Climate Change Response (Emissions Trading Scheme – Forestry Conversions) Amendment Act 2025

The Big Picture Climate Change

APR 2027

Bell Gully

6

6

Where to next for New Zealand’s Emissions Trading Scheme?

The government has affirmed the ETS as the central tool for New Zealand to reduce its emissions. But from forestry conversions to auction settings, there have been changes throughout the system.

With a number of changes coming into effect and more on the horizon in 2026, participants in the scheme and other stakeholders will need to stay informed.

We canvas the key changes that will impact on ETS participants.

Bell Gully

7

Streamlining the ETS — what the Efficiency and Effectiveness Bill means In November 2025, the government announced a new Climate Change Response (Efficiency and Effectiveness) Amendment Bill (the Efficiency and Effectiveness Bill), which proposes changes to the ETS aimed at improving how it operates.

Key changes proposed Moving the review of ETS auction price control and unit volume settings from an annual to a biennial process.

Adding flexibility for participants facing significant disruption.

Settings Simplifying processes for amending Emissions Reduction Plans and National Adaptation Plans.

Removing certain consultation requirements for emissions budgets and other documents.

Certainty

Decoupling the ETS from international obligations The government also announced plans to delink unit volumes and price control regulations from New Zealand’s international climate obligations. The Minister would no longer need to consider New Zealand’s nationally determined contribution (NDC) under the Paris Agreement when setting auction limits and price controls.

The government’s view is that the ETS is a domestic policy instrument and should be focused on domestic targets, while the first

NDC is an international target which was intended to be achieved through purchasing offshore units (although see further discussion on this below). This change was subsequently made alongside the changes to the 2050 target (discussed later).

Efficiency and Effectiveness Bill – timing: The government has indicated that the Efficiency and Effectiveness Bill will be introduced in early 2026. Whether it passes before the general election, scheduled for late next year, remains uncertain.

Removing the Minister’s ability to review eligibility for industrial allocations and allocative baselines for emissions-intensive, trade-exposed businesses. This means such businesses should not suddenly lose their allocation of NZUs, a change intended to avoid discouraging businesses from investing in emissions reductions for fear of losing their industrial allocation.

Bell Gully

The Big Picture Climate Change

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Streamlining the ETS — what the Efficiency and Effectiveness Bill means International settings for carbon markets

Opening the door to nonforestry carbon removals

While the government progresses changes to New Zealand’s ETS, uncertainty still remains around international carbon markets. Article 6 of the Paris Agreement allows for voluntary bilateral carbon trading as well as the establishment of a UN carbon credit mechanism. The rulebook for such international carbon markets was completed at COP29 in Baku last year.

The government also released a high-level assessment framework for non-forestry carbon removals in November.

However, significant work remains before any widescale adoption is seen. At November’s COP30 in Belém, 18 jurisdictions, including New Zealand, signed up to the Open Coalition on Compliance Carbon Markets initiative, which aims to establish a joint standard and connect various carbon trading systems.17 Such efforts are looking increasingly vital to allow countries (including New Zealand) to meet their NDCs under the Paris Agreement.

Notwithstanding these efforts, recent government statements suggest that New Zealand will not be turning to international carbon markets, even in the event that it cannot meet its first NDC under the Paris Agreement. In statements made in early December 2025, the Finance Minister and Climate Change Minister both indicated that paying for offshore mitigation was not part of the current plan and instead the focus would be on reducing domestic emissions.18 Bell Gully

The Big Picture Climate Change

Until now, forestry has dominated carbon removal opportunities under the ETS, with other forms of carbon removal receiving little recognition. The government is hoping to change that with the release of the new framework – or at least start the process.

The framework provides initial guidance for parties who are interested in participating in the ETS, contributing to New Zealand’s NDC or participating in voluntary carbon markets, by setting out: • The information parties should gather in respect of their proposals, supported by an online self-assessment tool (available in 2026).

• Scientific assessment criteria proposals would need to address.

• The key points parties need to establish before proposed non-forestry removals could be considered for inclusion in the ETS. The framework remains high-level at this stage. However, it signals the government’s willingness to do the work needed to bring other forms of carbon removals into the ETS. 9

Price, supply and market governance

These changes are intended to “address key market governance risks with lighttouch, low-cost regulation.”22

Auction settings and treatment of unsold volumes In August 2025, the government confirmed the ETS unit and price controls effective from 2026. These keep auction volumes and prices steady, with only minor adjustments.

A key change was made around the treatment of unsold auction volumes within each

Secondary market governance

calendar year. When an auction fails, any units carried over will only become available once the original volume at the subsequent auction has sold.19 This is intended to ensure that roll over of units does not make it harder for subsequent auctions to clear.

The new settings 20

The proposed approach: • Requires ETS market trading platforms to regularly report price and volume information to the government, and maintain a wider history of trading information. The information would not be published.

• Adds market conduct obligations to prohibit NZU price manipulation and false, unsubstantiated, or misleading conduct relating to NZU transactions.

2026

2027

2028

2029

2030

Auction floor price

NZ$71

NZ$75

NZ$78

NZ$82

NZ$87

NZUs available by auction (millions)

11.7

10.2

8.6

7.1

5.6

Industrial allocation (millions)

4.6

4.4

4.1

4.0

4.0

Overall limit on units (millions)

Having last consulted on this topic in early 2023, the government announced in May this year that Cabinet had agreed to changes to market governance for trading NZUs in the secondary market.21

16.3

14.6

12.7

11.1

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9.6

• Requires market participants to provide information to the government on request for market monitoring purposes. The Ministry for the Environment (MfE), the Environmental Protection Authority (EPA), Financial Markets Authority (FMA), Ministry for Primary Industries and Ministry for Business, Innovation and Employment would then be able to share information as needed.

• Requires market participants to record additional NZU trading information in the ETS Register, such as price and type of trade. Final requirements will be determined following engagement with the market. These changes wouldn’t come into effect immediately, they would be delayed until the ETS Register is ready to accommodate them.

Secondary market governance — timing Cabinet’s aim is to better align domestic market governance with international systems, while also reflecting New Zealand’s specific context and established market practices. To implement the changes, the government intends to introduce a Climate Change Response (Market Governance and Other Integrity and Efficiency Changes) Amendment Bill in late 2025 or early 2026.

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Farm to forest — curbing conversion Restrictions on the conversion of farmland to forestry took effect on 31 October 2025, following the passage of the Climate Change Response (Emissions Trading Scheme – Forestry Conversions) Amendment Act 2025.

The changes aim to protect productive land by limiting the extent to which farmland can be converted to exotic forest for registration in the ETS. Restrictions on the conversion of farmland to forestry took effect on 31 October 2025, following the passage of the Climate Change Response (Emissions Trading Scheme – Forestry Conversions) Amendment Act 2025.

The changes aim to protect productive land by limiting the extent to which farmland can be converted to exotic forest for registration in the ETS. The new provisions restrict land from being registered as post-1989 forest land under the ETS where: • The land was not forest land on 31 October 2025.

• The land falls into the first six classes under the Land Use Capability (LUC) farmland classification system.

• The forest species on the land are predominantly exotic.

Land excluded from LUC classes 1–6 includes indigenous forest land, exempt Māori land, high- or severe-erosion-prone land and Crown afforestation land.23 Where land falls within the above criteria, only up to 25% of an individual farm may be registered under the ETS – the remaining 75% can’t be registered. However, there will also be two ballots held annually to allocate permits for registering 7,500 hectares of Class 6 land, which offers another option to farmers holding such land. A national scale map will be used to make the initial assessment of LUC class, but landowners can map their land in greater detail at their own cost as long as they follow the methodology set out in regulations.

Investors in farmland should note these limits on future conversions, although the 25% allocation and Class 6 ballot do provide limited flexibility.

Bell Gully

Assessing carbon stored in forests

Forestry calculation changes – timing

In May 2025, MfE consulted on potential changes to the default carbon look-up tables as part of its Maximising Forest Carbon Programme. These tables are used by many forestry participants in the ETS to work out how much carbon is stored in their forests.

MfE’s website suggests that the Ministry is considering the feedback received from the consultation exercise and, if a decision is made to progress changes, this will be in place for late 2026 for use in the next mandatory emissions return period. Research into native forests is continuing.

The tables are important as most forestry participants operate on a small-scale, so rely on the default tables for such calculations. However, the tables have not been meaningfully updated since they were introduced in 2008.24 MfE considers that they are outdated, and don’t recognise the diversity of forest types present in New Zealand. The consultation focused on the default tables for exotic hard- and softwoods plus Pinus radiata.

The Big Picture Climate Change

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On target? Mixed news on emissions budgets25 ETS auction settings are underpinned by New Zealand’s emissions budgets. But how are we tracking as the first emission budget period draws to a close?

In October, MfE released its projections on New Zealand’s progress towards its climate budgets. Those projections show New Zealand achieving both the first and second emissions budgets with a small buffer.

Budget

Projection

First emissions budget (2022 – 2025)

290Mt

282.2Mt

Second emissions budget (2026 – 2030)

305Mt

300.5Mt

Mt= megatonnes of carbon dioxide equivalent

Projections indicate that New Zealand could meet its net zero target for long-lived gases and be slightly below net zero generally by 2050.

The country is also on track to meet its 2050 biogenic methane target (a 24% reduction). However, the 2030 target would be narrowly missed. Officials acknowledge long-range projections carry a high degree of uncertainty. The projections also rely on additional measures being taken to reduce emissions beyond current policy settings – without them, the net zero target will not be met.

Bell Gully

The picture isn’t quite as positive elsewhere. Current estimates show New Zealand missing its third emissions budget (2031 – 2035) by a reasonable margin, emitting between 246 and 258 Mt, against a budget of 240Mt. International-facing targets also appear challenging.

Projections put New Zealand’s emissions at 660Mt against a provisional budget of 575Mt for its nationally determined contributions for 2021 – 2030, and 55Mt against a provisional point-year budget of 43Mt for 2030.

Notably, these projections are based on estimates of carbon price peaking at NZ$80 in 2030 and then falling to NZ$54 by 2050.26

Biogenic methane target revised In October 2025, the government announced changes to New Zealand’s key 2050 targets. The net zero target for long-lived gases (greenhouse gases other than biogenic methane) has been retained, but the biogenic methane target will be changed. The 2030 target of 10% less than 2017 emissions by 2030 is unchanged. But instead of the current target for reductions of 24 to 47% less than 2017 emissions by 2050,27 the biogenic methane component of the 2050 target will be revised to between 14 and 24% below 2017 levels by 2050. This amendment was ultimately made via a Climate Change Response (2050 Target and Other Matters) Amendment Act 2025, which was passed under urgency in December.

The Big Picture Climate Change

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What’s changing for - climate-related disclosures Bell Gully

The Big Picture Climate Change

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The proposed changes offer relief for managers of managed investment schemes as well as the listed issuers who will now fall outside the scope of the regime. Climate reporting entities and directors still subject to the regime will benefit from lower liability settings.

Sweeping changes to climaterelated disclosures regime New Zealand was at the leading edge of climate risk reporting when it became the first country in the world to introduce legislation requiring mandatory reporting for the financial sector in 2021. Four years on, significant changes have been proposed to the scope of the climate-related disclosures (CRD) regime.

The changes will limit the reach of the CRD regime by adjusting the thresholds for who is in the scheme, and who is not, and place managed investment schemes outside its scope.

Regulators have described the initial introduction of mandatory climate-reporting legislation as a means to help address an “information gap” that drove overvaluation of emissions-intensive activities, potentially resulting in mispricing of assets and misallocation of capital.28 Even so, we believe it is right to refine the regime where appropriate.

The proposed changes respond to market feedback and are part of broader efforts aimed at reducing compliance burdens and strengthening New Zealand’s capital markets.

However, while expectations were set by a consultation that closed in February 2025, what emerged in late October went further than what was initially proposed in some areas.

Bell Gully

CRD regime changes — at a glance Significant jump in reporting thresholds The mandatory reporting threshold for listed issuers will rise substantially: from market capitalisation of NZ$60 million to NZ$1 billion for equity and debt issuers. This is a substantial departure from the consultation’s proposed upper bound of NZ$550 million. Issuers below the new threshold may still choose to report voluntarily.

Looser evidence and substantiation requirements Acknowledging the inherent uncertainty of climate reporting, the Government confirmed directors and CREs will not have to meet the same standard of evidence for climate disclosures as they do for financial disclosures, noting climate reporting involves “futurefocused and uncertain” information while financial reporting draws on historic data.

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Softer liability settings Directors will no longer be automatically liable for breaches of reporting obligations by climate reporting entities (CREs) under the changes proposed.

The current regime deems directors liable for breaches of certain climaterelated disclosure obligations by the CRE.

Managed investment schemes excluded Managers of managed investment schemes (MIS) with more than NZ$1 billion in total assets are currently required to prepare annual climate statements. Under the proposed reforms, MIS will be removed entirely from the CRD regime. This is a notable shift from the consultation, which proposed raising the threshold to NZ$5 billion rather than outright exclusion.

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The missing defence that could support sustainability goal-setting

During the consultation, we advocated for change around the lack of a ‘due diligence’ defence for CREs. That type of defence wasn’t included in the changes eventually proposed.

The October announcement instead confirmed that liability for misleading or deceptive conduct, and for false or misleading statements under Part 2 of the Financial Markets Conduct Act, will remain entwined with the CRD regime. So is liability for unsubstantiated representations.

We still consider that it would be sensible for the regime to ensure that. If a CRE takes all reasonable steps to ensure that climate statements are not false, misleading or unsubstantiated, no liability should arise. The introduction of a due diligence defence would enhance the CRD regime.

That means, even if a CRE takes all reasonable steps to avoid wrongdoing, there isn’t any defence to these liabilities, now or under the changes proposed.

Climate-related disclosure – what’s next?

Climate reporting entities are often under pressure to set and publish ambitious climate targets: from shareholders, customers and climate activists. But targets are by their nature forward-looking, based on everevolving information over long time-frames.

The absence of such a defence therefore creates an unreasonably strict regime, which may hold a CRE back from being publicly ambitious about its sustainability goals and what it could reasonably be capable of achieving.

Bell Gully

The Government intends to progress CRD changes through the Financial Markets Conduct Amendment Bill, with passage expected in 2026.

The Big Picture Climate Change

Meanwhile, for CREs and directors still subject to the regime, other reforms and potential reforms remain relevant:

XRB consultation The XRB recently extended adoption provisions (for disclosure of anticipated financial impacts, and disclosure and assurance of scope 3 emissions) as well as potential amendments to achieve closer alignment with climate reporting regimes overseas.

FMA consultation The FMA recently consulted on draft “Ethical Disclosure” Guidance for the marketing of ESG financial products.

15

Spotlight on -

Bell Gully

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Spotlight on greenwashing: a new ESG taxonomy

ESG claims continue to be closely scrutinised by regulators, investors, and in the courts, keeping concern about missteps high on the radar for many New Zealand businesses.

From misleading disclosures, to overstated climate credentials, businesses face reputational and financial consequences if they fall short.

Rising awareness of ‘greenwashing’ risks in the New Zealand market in the last couple of years, has been followed closely by a spotlight on ‘greenhushing’, where businesses may not communicate around sustainability efforts for fear of negative consequences.

Against this backdrop, development of draft criteria for a sustainable finance taxonomy for New Zealand to offer a clear, credible framework for classifying ‘green’ activities in finance is a step forward. In reducing ambiguity, a taxonomy can lessen the risk around making misleading claims, and potentially provide businesses with the certainty needed to make sound claims with confidence. In finance, that also provides the means to accurately direct funds towards sustainable activities.

The Aotearoa New Zealand Sustainable Finance Taxonomy (the Taxonomy) will provide a classification system to identify economic activities that contribute to New Zealand’s environmental objectives. Its purpose is to facilitate the flow of capital toward sustainable practices across relevant industries.

In June, the Centre for Sustainable Finance (CSF) conducted a public consultation on the criteria for the Taxonomy, under the direction of the Minister of Climate Change. This initial consultation focused on the current priority sectors of agriculture and forestry sectors, with a second consultation in September focused on climate change adaptation and resilience criteria in the agriculture and forestry sectors.29 The Taxonomy is likely to eventually expand to other industries such as construction, transport, and energy.

Bell Gully

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Spotlight on greenwashing: a new ESG taxonomy What is the New Zealand Sustainable Finance Taxonomy?

The Taxonomy is intended to create a classification system for various economic activities based on environmental performance. As with similar models overseas, its purpose is to reduce uncertainty and complexity in assessing the sustainability credentials of investments, and so support the flow of private capital towards businesses actively transitioning to a low-emissions, climate-resilient economy.

More than 50 jurisdictions are developing sustainable finance taxonomies. The Taxonomy is designed to align with international frameworks while remaining relevant to New Zealand’s domestic context.

The Taxonomy will cover: • ‘Green’ finance –financial activities aimed at supporting environmentally beneficial projects.

• ‘Transition’ finance – financial flows that help high-emitting sectors or businesses move towards low-carbon or net-zero pathways. Transition finance will be especially relevant for hard-toabate sectors such as agriculture and construction.

While it is expected to be voluntary, it is also likely to be a key tool for financial institutions, investors, and insurers in capital allocation, product development, risk assessment, and sustainability reporting. If widely adopted by lenders and investors, there will be significant value in conforming in order to access the lower cost of capital available to taxonomyaligned businesses.

What do we know from consultations so far?

Which industries might be affected?

• The methodological approach to defining ‘green’ and ‘transition’ activities, which will be relevant to all sectors for which mitigation criteria are developed.

Expressions of interest to join sector-specific Technical Advisory Groups Other sectors likely to be designated in due course include: • Construction and real estate • energy

To date consultation has focused on: • Criteria for activities which make a substantial contribution to climate change mitigation activities in the agriculture and forestry sectors.

As with some overseas models, activity must meet:

What’s next?

A final criteria report for the agriculture and forestry sectors is expected by the end of 2025 or early 2026.

Public consultation will then open on the draft Taxonomy criteria for the energy sector, covering climate change mitigation, adaptation and resilience, in June 2026. That will be followed by draft Taxonomy criteria for construction and buildings sector in July.

Submissions will help shape the final Taxonomy which is expected to be published at the end of 2026.30

• “Do no significant harm” criteria to safeguard against other negative environmental outcomes.

• Minimum social safeguards (to protect “social outcomes” and objectives).

• agriculture • fisheries • transport • industrial manufacturing Banks, fund managers and other investors will also have an interest as a taxonomy reduces their risks of promoting ESG funds, green bonds and sustainability-linked loans involving the relevant sectors.

Bell Gully

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Greenwashing allegations and claims in the courts Greenwashing remained a key focus for regulators globally through 2025, as seen in enforcement actions in Australia and Germany. As detailed in our earlier publication: Greenwashing update: rising penalties, fines have followed, including a €25 million fine imposed on asset manager DWS for misleading ESG fund claims.

However, greenwashing isn’t solely a regulatory concern. It is increasingly the subject of litigation in both Australia and New Zealand, often initiated by environmental advocacy groups.

Z Energy settles greenwashing claims In November, Z Energy announced in a press release that it had settled a claim brought against it by Lawyers for Climate Action New Zealand, Consumer NZ and the Environmental Law Initiative, alleging that Z had engaged in greenwashing through various statements and advertising campaigns.

The proceedings, filed against Z Energy in November 2023, challenged the accuracy of a number of advertisements relating to aspects of Z Energy’s emissions reductions initiatives, including the statement that it The Big Picture Climate Change

was “getting out of the petrol business”.

The plaintiffs, who had first complained to the Commerce Commission, commenced their own proceedings after the Commission decided not to take any action. They sought declarations that the claims were misleading and had breached the Fair Trading Act 1986, and orders that corrective advertising be published.

After two years of procedural wrangling, the claim has now been settled with no admission of liability by Z Energy, and no payment being made to the plaintiffs. Z Energy maintained that it had not misled consumers, but did apologise publicly for any confusion caused by its advertising campaign, clarifying that its statements about “getting out of the petrol business” were intended to be aspirational and provocative in the context of Z’s low carbon transition strategy and it did not intend to stop selling petrol any time soon.

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Greenwashing allegations and claims in the courts Australian parallels Across the Tasman, EnergyAustralia, one of Australia’s largest energy retailers (and greenhouse gas emitters), earlier this year settled Federal Court proceedings brought against it by climate advocacy group Parents for Climate. The group accused the energy company of ‘greenwashing’ in marketing certain products.

The case, originally filed in August 2023, settled just days before a two-week hearing was due to commence. It had challenged the legality and accuracy of EnergyAustralia’s marketing of its “Go Neutral” gas and electricity products, which were promoted as “carbon neutral” through the use of carbon offsets using carbon credits in the Australian Carbon Credit Unit (ACCU) Scheme. It was alleged the marketing misled consumers into believing that their energy use had no negative environmental impact because of the company’s offsetting practices, or, indeed, even had a positive impact. Parents for Climate maintained that this wasn’t the reality.

The case was brought under section 18 of the Australian Consumer Law, which like New Zealand’s own Fair Trading Act, prohibits misleading or deceptive conduct in trade or commerce. Parents for Climate sought declarations that customers had been misled, and sought an order restraining EnergyAustralia from making “carbon neutral” or similar statements to describe its “Go Neutral” product.

As part of the settlement, EnergyAustralia made several admissions and commitments.

They included publicly admitting that its “Go Neutral” marketing could have been clearer and acknowledging that carbon offsetting does not prevent or undo the environmental harms caused by burning fossil fuels.

EnergyAustralia also conceded that carbon offsetting is not the most effective way to help customers reduce their emissions and that its energy supply remains largely fossil fuel-based.

Bell Gully

Ongoing litigation: Greenpeace v Fonterra In September 2024, Greenpeace Aotearoa began proceedings against Fonterra, alleging greenwashing over Anchor butter packaging, which included the words “100% New Zealand grass-fed”. Greenpeace argues this is misleading because Fonterra’s own grass-fed standard allows up to 20% of a cow’s diet to consist of imported palm kernel expeller (PKE), which Greenpeace says is linked to rainforest deforestation and other climate change impacts. Declarations as to the misleading nature of the packaging and injunctive relief preventing further use of the phrase in question are sought.

While the case is ongoing and will be closely watched, Fonterra, which denies the claims, has confirmed in a statement of defence filed earlier in 2025 that the packaging complained about is no longer in use.

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ICJ leads the way in global climate litigation Key decisions on the obligations of States and corporate liability mean 2025 has been another interesting year for climate litigation globally.

In July, the International Court of Justice (ICJ) issued a historic advisory opinion on States’ climate obligations and the legal consequences of failing to comply with them.31 Elsewhere, the German courts have led the way in addressing corporate liability for climate change across national boundaries.

Meanwhile, in New Zealand, the government remains the principal target of climate litigation.

ICJ Advisory Opinion on Climate Change The ICJ’s advisory opinion was a long time coming. The questions of what States’ obligations are in respect of climate change under international law, and the legal consequences of failure to comply with them, were referred to the Court by the UN General Assembly in March 2023. In their unanimous decision (only the fifth such decision in the Court’s eighty year history), the full bench of 15 judges found that States are subject to binding obligations in respect of climate change and these obligations can be enforced by other States.

The Court found: • Climate treaties, including the UN Framework Convention on Climate Change, impose binding obligations on States. Parties to the Paris Agreement must act with due diligence in taking steps to adequately contribute to the 1.5°C temperature goal, maintain their nationally determined contributions and pursue measures capable of achieving them.

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• States have obligations under customary international law, including a duty to prevent significant harm to the environment by acting with due diligence and using all available means to prevent activities within their control from causing significant harm to the climate. This standard is described as “stringent”.32 States also have a duty to co-operate with each other in good faith to prevent serious climate harm.

• Those States that are party to the UN Convention on the Law of the Sea also have an obligation to adopt measures to preserve the marine environment, including from the effects of climate change.

• They have obligations under international human rights law, with the protection of the environment and protection of human rights considered interdependent.33 According to the Court, the wrongful act in question is not the emission of greenhouse gases itself, but the breach of these obligations. It observed that States are obliged to regulate private actors as part of their due diligence, and may therefore be responsible for the harm caused by private entities if they have not taken enough action to stop that harm.

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Where a State breaches any of the above obligations, that constitutes an “internationally wrongful act entailing the responsibility of that State,”34 the Court found. The legal consequences of that may include: • An obligation to cease the wrongful act or omission.

• Providing assurance or guarantees that they will not be repeated.

• Making “full reparation to injured States through restitution, compensation and satisfaction”, where the general conditions on the law of State responsibility are satisfied. This generally includes showing a sufficiently direct and certain causal link between the injury and the alleged wrongful act.35 The ICJ’s opinion is non-binding and cannot be enforced directly. However, it lays the foundation for future action to require States to comply with their obligations.

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A key case on corporate liability One of the most closely watched climate cases of the past year played out in the German courts.

Saúl Luciano Lliuya, a farmer and mountain guide from Peru, sued RWE AG, a German utility company, alleging it had materially contributed to global warming and accelerated the melting of glaciers above his home of Huaraz, increasing the risk of flooding from a nearby glacial lake. Central to Mr Lliuya’s claim was his argument that RWE should contribute a share of local costs to reduce the risks from the lake that was proportionate to its share of global emissions.

The Regional Court of Essen initially dismissed the claim on the basis that the harm caused was too removed from RWE’s actions. However, on appeal, the Higher Regional Court of Hamm found the claim was in principle justiciable (i.e. the court could examine it), accepting that science could potentially support claims of causation on a proportionate basis.36 It commissioned extensive expert evidence for the next phase of the case, including on glacial dynamics, flood risk and apportionment of responsibility for climate change.

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Ultimately, after reviewing this evidence, the court rejected Mr Lliuya’s appeal.

While the distance from the defendant’s powerplants to his property didn’t prevent the claim, the court found there was no concrete danger to his property because the prospect of the glacial lake reaching his house in the next 30 years was about one percent.37 Despite this outcome, the case demonstrates overseas courts’ willingness to consider cross-border claims for harm caused by climate change. By being willing to consider evidence of harm at a specific site, the German courts have opened the door to claims seeking contributions to targeted adaptation measures, rather than sweeping damages claims.

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New Zealand climate litigation We have addressed greenwashing cases elsewhere in this report.

Beyond those claims, climate-related decisions remain relatively infrequent. However, two decisions this year suggest that Ministers and government agencies remain the principal targets of climate litigation, while the courts continue to recognise decision-maker discretion.

Lawyers for Climate Action NZ Inc v Climate Change Commission38 In this case, the Court of Appeal considered LCANZ’s challenge to the Climate Change Commission’s advice on emissions budgets and whether New Zealand’s nationally determined contribution (NDC) was compatible with global efforts to limit warming under the Paris Agreement.

LCANZ argued that the Commission’s advice was based on an error, that the budgets failed to consider the 2050 target or goals of the Paris Agreement, that the Commission was required to use a landbased accounting methodology (rather than modified activity-based), and that its approach was unreasonable. While the Court of Appeal agreed that the Commission’s advice could be reviewed, it considered that there was no error or incorrect accounting method. The Court further emphasised that the Climate Change Response Act 2002 has a dual purpose, in setting the 2050 target and contributing to the goal of limiting warming to 1.5°C under the Paris Agreement. However, these do not set a single “bottom line” for each budget period and there were various approaches a decision-maker could take.39 Finally, it concluded that the Commission’s approach was not unreasonable.

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Movement v Waka Kotahi40 Here the Court of Appeal considered a judicial review by Movement on the basis that NZTA’s National Land Transport Programme had failed to sufficiently address carbon emissions. In the event, the issuing of a new Government Policy Statement following the last election had rendered many of the issues before the Court moot. The Court did find that decision-makers under the relevant statute could consider climate change objectives, but they were not required to.

What lies ahead?

Cases underway which will be closely scrutinised in 2026 and 2027 are:

LCANZ v Minister of Climate Change41 Lawyers for Climate Action NZ and the Environmental Law Initiative have filed judicial review proceedings against the Minister, alleging that: • The Government unlawfully altered the first emissions reduction plan (ERP) by discontinuing around 35 measures without the meaningful public consultation required for more-thanminor changes. The result is an unlawful plan lacking coherence and internal consistency.

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• The second plan, ERP2, is not a lawful plan “for meeting” the next budget because it relies heavily on offsets (projecting ~700,000 ha of new forestry by 2050), treats sequestration as fungible with gross reductions, and adopts a “wait-and-see” risk approach with insufficient buffer. ERP2 also assumes roughly 95% of reductions arise from a modelled “emissions baseline” rather than identified policies and strategies. As such, the plan is unlawful. The applicants further allege that the process followed in consulting on the plan was unlawful and the Minister’s decision wasn’t based on an accurate or adequate report from officials.

The case is expected to be heard early next year.

Smith v Fonterra This key piece of climate litigation has been covered extensively in previous Bell Gully articles. The trial is currently scheduled for April 2027.

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A new approach - natural hazard risks Bell Gully

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National adaptation framework — a new approach to managing natural hazard risk, costs The launch of a landmark framework that establishes a long-term system for managing risks from floods, storms, and other natural hazards marks a critical step in shaping how New Zealand responds to climate-related challenges and natural hazard risks.

The National Adaptation Framework (NAF) released in October 2025 is built around four key pillars, underpinned by sixteen actions.

Together these prioritise nationally consistent hazard data, clearer mandates for councils, market signals to guide adaptation and a new approach to cost sharing that involves development levies.

The framework echoes the four pillars seen in earlier advice from experts in the Independent Reference Group in its Proposed Approach for New Zealand’s Adaptation Framework report.

This drew wide attention in recommending a 20-year transition away from post-event government buyouts, in contrast to the approach taken after major natural disasters in recent years.

Who is going to pay?

While this approach was not explicitly reiterated in the NAF, the policy direction appears to have been echoed in clearer mandates for councils to plan, a beneficiarypays orientation, a shift away from propertyvalue-linked buyouts and towards enabling insurance and lending markets to price risk and reward reduction.

Climate Change Minister Simon Watts has signalled that the government isn’t likely to provide financial assistance to homeowners based on a full pre-event property valuation. The new framework trends towards allowing the market to dictate adjustment to risk, and towards property owners shouldering the financial consequences of natural hazard events.

Taken together with this advice, the framework has significant implications for insurers and lenders, developers, local authorities, Māori, private companies and individuals alike.

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The four pillars of the National Adaptation Framework 2 Roles and responsibilities

1 Risk and response information sharing There is a strong focus on readily available, regularly updated and nationally consistent natural hazard information. A raft of actions are intended to accomplish this, including development of a National Flood Map by 2027, new hazard datasets and new risk standards. The Natural Hazards Portal will be updated, investment made in high quality risk information and science, innovation and technology reforms are planned.

Equal access to quality information will support risk management by government, financial institutions and insurers, and enable property owners and developers to make informed decisions aligned to their risk appetite.

Stakeholders will also want to know how their responsibility is defined.

Central government is to provide regulatory and institutional settings, local authorities are to lead local responses, and the private individual or company is left to manage their own risk. The definition of these roles and responsibilities will be achieved through: • The establishment of a new national direction for natural hazards • The development of spatial plans, delivered through the resource management system reforms • Amendments to the Climate Change Response Act 2002 requiring local authorities to develop adaptation plans in priority areas • Investment into preparation and response to emergency with the Emergency Management Investment and Implementation Roadmap

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It isn’t possible to make an informed decision without information. This premise has led a strong direction to prioritise natural hazard information.

3

4

Investment in risk reduction

Cost-sharing pre- and post-event

The NAF shifts spending towards reducing risk before events occur.

Key actions include applying the Funding and Financing Framework to guide investment decisions and reduce fiscal exposure, deploying the NZ$1.2 billion Regional Infrastructure Fund to bolster regional resilience, providing regulation to guide council decision-making on adaptation, and proactively managing Crown assets.

One cost-sharing measure is actioned in the NAF – a new development levy system as part of Going for Housing Growth to ensure developers pay their fair share of infrastructure costs.

The Government will also deliver new tools to support recovery decisions following significant severe weather events. In the absence of any clear centrally-led funding scheme, the market will dictate risk adjustment.

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What does the NAF mean for stakeholders?

What’s next?

The four pillars are intended to construct a robust system, designed not only to help New Zealand endure the growing natural hazard risks but to withstand the changing tides of government.

It’s likely there will be consensus on the need for robust information systems and improved policy around the high risk areas of adaptation planning.

Together, the NAF and IRG Report give rise to a number of new considerations:

Insurers and lenders

Developers

Priority is given to the market to guide adaptation.

As some properties become uninsurable, insurers and lenders have discretion to push growth and development away from high-risk areas.

Local authorities Local authorities should expect a steady flow of centrally-led policy directives and, particularly in high-risk areas, an obligation to develop revised

But other topics are likely to remain contentious - such as the notable omission of any discussion on managed retreat and a phase out of post-disaster government buyouts.

There are also a number of developments and data updates alluded to by the NAF, which stakeholders will want to watch, including:

One key point for developers is that the development levy system appears to be the key funding mechanism for resilience infrastructure, potentially creating a heavy financial

• Phase Three of the Resource Management reforms. The Government introduced RMA replacements the Natural Environment Bill and the Planning Bill in December 2025. The framework for the creation of spatial plans is contained here.

burden.

Māori

• The first National Policy Statement for Natural Hazards as part of the national direction (programme alongside Phase Three reforms).

Individuals and private companies

Although the IRG Report made references to prioritising ancestral whenua, no such priority was reiterated in the NAF.

Should consider a shift toward managing their own risks and limiting their post-disaster

spatial and adaptation plans.

fiscal exposure.

• The framework for the new development levies system.

• The first iteration of the National Flood Map by 2027.

• Regulations to ensure councils weigh up costs and benefits of climate adaptation options.

• Updates to hazard datasets and the Natural Hazards Portal.

• Amendments to the Climate Change Response Act requiring local authorities to develop adaptation plans.

With an election coming next year, climate change response will remain a significant political touchstone. Opposition parties have indicated they are not supportive of everything contained in the new framework, but they are yet to re-open the possibility of comprehensive managed retreat.

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Our practice

Our team brings expertise and adaptability drawn from our role at the forefront of climate change action in New Zealand for more than 20 years. What we’ve learned is embedded across the broad range of the practice areas needed to meet today’s challenges, and we deliver clear commercial and strategic advice on mandatory reporting requirements, greenwashing, climate litigation, and directors’ duties to consider climate-related risks. Having advised on core climate change legislation and the development of New Zealand’s Emissions Trading Scheme, the world’s first avoided deforestation project and pioneering emissions trading activity, we now look ahead to climate adaptation, the energy transition and the opportunities that are arising alongside the challenges.

We can provide you with advice on: • Substantiating environmental claims and avoiding ‘greenwashing’ • Directors’ duties, statutory due diligence and disclosure obligations

INDEPENDENT RECOGNITION • Climate Change (the only New Zealand team ranked.)

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Our team

CLIMATE CHANGE, MANAGED RETREAT, AND INFRASTRUCTURE

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Our thanks to senior associates Dr Laura Hardcastle and Matthew Gale for major contributions to this report, as well as to graduate Minna Reid and lawyer Caroline Enright for their assistance.

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Acknowledgements

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Endnotes 1.

Ministry for the Environment “Our journey towards net zero New Zealand’s second emissions reduction plan 2026–30” (11 December 2024) www.environment.govt.nz

2.

Hon Simon Watts “Setting New Zealand’s second international climate target” (press release, 30 January 2025) www.beehive.govt. nz

3.

4.

5.

6.

7.

8.

9.

Ministry for the Environment “National Policy Statement for Renewable Electricity Generation” (29 May 2025) www.environment.govt.nz

10.

The Financial Markets Authority – Te Mana Tātai Hokohoko “‘No action’ relief for climate reporting entities due to be relieved of mandatory reporting ” (28 October 2025) www.fma.govt.nz

11.

Hon Todd McClay, Hon Simon Watts, and Hon Andrew Hoggard “Government sets methane targets for 2050” (press release, 12 October 2025) www.beehive.govt.nz

12.

Centre for Sustainable Finance: Toitū Tahua “Public consultation opens on the Aotearoa New Zealand Sustainable Finance Taxonomy” (16 June 2025) www.sustainablefinance.nz

13.

Ministry for the Environment “Climate Change Commission annual emissions monitoring report released” (25 July 2025) www.environment.govt.nz

14.

He Pou a Rangi Climate Change Commission “Next steps critical for delivering Aotearoa New Zealand’s climate goals” (25 July 2025) www.climatecommission.govt.nz Obligations of States in Respect of Climate Change (Advisory Opinion) [2025] ICJ Rep 187. www.icj-cij.org/case/187 The Financial Markets Authority – Te Mana Tātai Hokohoko “Consultation: Proposed guidance for ethical investing disclosure” (24 September 2025) www.fma.govt.nz Ministry of Business, Innovation and Employment “Mandatory climate-related disclosures” (13 December 2024) www.mbie.govt.nz

External Reporting Board “Adoption of Aotearoa New Zealand Climate Standards” www.xrb.govt.nz Ministry for the Environment “Government announces a series of changes to NZ’s climate change law” (4 November 2025) www.environment.govt.nz

20.

Ministry for the Environment “Annual updates to emission unit limits and price control settings” (19 August 2025) www.environment. govt.nz

21.

Ministry for the Environment “Market governance for the New Zealand Emissions Trading Scheme” (27 May 2025) www.environment.govt.nz

22.

23.

Ministry for the Environment “Market governance for the New Zealand Emissions Trading Scheme” (27 May 2025) www.environment.govt.nz Ministry of Primary Industries “LUC class restrictions on post-1989 forest land” www.mpi.govt.nz

30.

Centre for Sustainable Finance: Toitū Tahua “Development timelin” www. sustainablefinance.nz; and “NZ Taxonomy ag/ forestry sector second public consultation info webinar” (21 September 2025) www. youtube.com

31.

Obligations of States in Respect of Climate Change (Advisory Opinion) [2025] ICJ Rep 187.

32.

At [138].

33.

At [144].

34.

At [457]

35.

At [457]

36.

Luciano Lliuya v. RWE 5 U 15/17 OLG Hamm.

37.

“Dismissal of the appeal in the proceedings of the Peruvian mountain guide Liluya against RWE” (28 May 2025). Available at: Higher Regional Court of Hamm: Dismissal of the appeal in the proceedings of the Peruvian mountain guide Lliuya against RWE

24.

Ministry of Primary Industries “Maximising forest carbon” www.mpi.govt.nz

25.

Ministry for the Environment “Updated emissions projections to 2050 released” (12 October 2025) www.environment.govt.nz

26.

Ministry for the Environment “New Zealand’s projected greenhouse gas emissions to 2050” (12 October 2025) www.environment.govt.nz

38.

Lawyers for Climate Action NZ Inc v Climate Change Commission [2025] NZCA 80

27.

Climate Change Response Act 2002, s 5Q.

39.

At [108].

Mayara Souto and Fabiana Otero “Carbon Market Coalition Welcomes 18 Member Countries at COP30” (15 November 2025) COP30 www.cop30.br

28.

Climate-related Disclosures Regimes: What you need to know (External Reporting Board and Financial Markets Authority, June 2024) at 4.

40.

[2025] NZCA 86

41.

18.

Kate Newton “Impossible to meet Paris Agreement targets without buying offshore carbon credits – experts” RNZ (4 December 2025) www.rnz.co.nz

29.

Lawyers for Climate Action NZ “Climate Litigation: We’re suing the Climate Minister of the government’s emissions reduction plan” (10 June 2025) www.lawyersforclimateaction. nz

19.

Climate Change (Auctions, Limits, and Price Controls for Units) Amendment Regulations 2025.

15.

16.

17.

He Pou a Rangi Climate Change Commission “Our upcoming work” www.climatecommission.govt.nz He Pou a Rangi Climate Change Commission “Emissions reduction monitoring reports” www.climatecommission.govt.nz He Pou a Rangi Climate Change Commission “2026 Progress report: National Adaptation Plan” www.climatecommission.govt.nz

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Centre for Sustainable Finance: Toitū Tahua “Public consultation open on second draft of the NZ Taxonomy” (22 September 2025) www.sustainablefinance.nz

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