Guidance for keeping proper climate-related disclosure records

Guidance for keeping proper climate-related disclosure records

Measuring your Scope 1, 2 and 3 greenhouse gas emissions according to the Greenhouse Gas Protocol (GHG Protocol) is a complex process. There are many different activity-types for which emissions data must be collected and measured, and record-keeping is therefore key.

We recently shared how New Zealand is one of the first jurisdictions to introduce mandatory climate reporting for years ending 31 December 2023. In light of this development, the New Zealand Financial Markets Authority published Guidance for keeping proper climate-related disclosure records (Guidance) to help entities meet their statutory obligations with respect to keeping proper climate-related disclosure records.

While the laws about climate-related disclosures and obligations to keep proper climate-disclosure records may differ from country to country, we believe that in the interim, this New Zealand Guidance may be a useful resource for entities on their climate-reporting journey as it contains key principles and considerations that can be applied by any entity. Applying this Guidance, entities should be asking the following questions to ensure that systems and processes result in proper record-keeping for your climate-related disclosures.

Key questions for keeping proper climate-related disclosure records

  1. Are records readily identifiable and comprehensible? Records should be in a format that can be made available for inspection, or easily converted into such a format (this is also important if the information is subject to assurance requirements)
  2. Are records kept in English (or the equivalent language relevant to jurisdiction)?
  3. Do records provide evidence of materiality considerations?
  4. Have records been maintained within an effective system of controls to support the integrity, accuracy and timeliness of records and reporting systems?
  5. Do you have appropriate protections and safeguards for records, including security, cyber risk and change controls?
  6. Do records kept by a third party comply with the entity’s legal obligations to provide records for inspection?

Need help with your record-keeping for climate-related disclosures? 

If you need a hand developing or reviewing your climate reporting records and systems of controls, our IFRS & Corporate Reporting team can help. Contact us today.