RIAA welcomed the NZ Government’s commitment to ensure the Regime is fit-for-purpose and meets its ultimate to support the allocation of capital towards activities that are consistent with a transition to a low-emissions climate-resilient future. RIAA agrees that there have been challenges with the CRD Regime. These challenges require considered evidence-based policy solutions.

RIAA generally supports aligning the CRD Regime with both Australia and global standards. However, to maintain the integrity and credibility of the CRD Regime, any changes (legislative or otherwise) must remain relative to the NZ market – that is, the CRD Regime should be capturing entities which are of a size and significance to the objectives of the Regime for the NZ economy.

We make several recommendations in response to the consultation:

• Bring forward the XRB post-implementation review of the CRD framework.
• FMA to provide strong and ongoing guidance on how to meet the obligations of the CRD Regime, including with regards to existing legal obligations.
• Policy certainty and simplicity to prevent unclear timeline implications and disconnected stop-start reporting from the proposed changes, especially when considered together with corresponding Australian requirements, and in relation to the changes to thresholds and proposed modified liability provisions.