Voluntary climate disclosure integration

The challenge

That landscape shifted in October 2025, when the Government proposed raising the mandatory CRD threshold. The change took both CCHL and LPC outside the mandatory regime, but LPC’s commitment to transparency didn’t change. LPC remains committed to voluntary disclosure to meet CCHL’s expectations, support its own strategic goals, and serve the investors, lenders, and community stakeholders who rely on the port.

The existing disclosure model had a structural problem. A standalone CRD document that cross-referenced the Annual Report had become fragmented, duplicative, and time-consuming to rebuild each year. As LPC prepared its FY26 Annual Report, it had a clear opportunity to fundamentally redesign its approach.

The challenge was substantial. LPC’s five-capitals reporting framework didn’t map neatly to the four NZ CS 1 thematic areas. Continuing legal obligations under the Financial Markets Conduct Act and the NZX Corporate Governance Code still applied to voluntary reporters, meaning careless framing carried real legal risk. The finance team also needed to be drawn actively into the CRD process, particularly for the Financial Statements Note 1.

LPC needed expert guidance to navigate all of this within a tight annual reporting timeline.

Tonkin + Taylor delivered a structured two-phase programme, drawing on deep expertise in climate-related financial disclosures and New Zealand regulatory requirements.

Phase 1 began immediately after engagement. Tonkin + Taylor completed a comprehensive desktop review of LPC’s FY25 Annual Report and CRD against best-practice guidance for voluntary reporting. We mapped existing climate content against the four NZ CS 1 thematic areas, identified gaps and priorities, and benchmarked LPC’s approach against comparable New Zealand organisations, including Port of Tauranga and Meridian Energy. That benchmarking confirmed that no comparable New Zealand port had yet fully integrated substantive climate disclosure throughout its annual report. LPC had an opportunity to lead the way.

Phase 2 delivered the architecture to do exactly that. Tonkin + Taylor designed a layered integration model with a three-level disclosure hierarchy calibrated to serve different reader audiences.

A section-by-section integration wireframe then guided LPC’s reporting team through eight Annual Report sections, specifying what content should appear, at what depth, in what format, and how sections cross-reference each other.

We also mapped the continuing legal obligations that apply to voluntary reporters and provided precise language guidance at every sensitive point in the report. This ran from the voluntary nature statement and forward-looking disclaimer through to NZ CS 1 reference language designed to avoid inadvertent compliance claims. Each element was designed to reduce exposure under the Financial Markets Conduct Act’s fair dealing provisions while maintaining credibility with sophisticated stakeholders.

As a final step, Tonkin + Taylor reviewed LPC’s draft FY26 Annual Report against the wireframe recommendations. We confirmed that the draft had largely incorporated the structured approach and provided targeted guidance on the quality of physical risk disclosure, GHG comparative data, and the evolution of the transition plan, all consistent with the Financial Markets Authority’s May 2026 CRD Insights Report.

LPC’s FY26 Annual Report breaks new ground. The integrated disclosure approach, with climate content embedded throughout the report at three distinct levels of depth, makes LPC the first comparable New Zealand port to move beyond cross-referencing a standalone CRD document. It’s a meaningful step forward for voluntary disclosure practice in the New Zealand port and infrastructure sector.

The reusable, templated three-level framework is designed to reduce the reporting team’s effort year on year. What was previously a labour-intensive, annually rebuilt standalone document becomes an efficient, structured process with language guidance, a cross-referencing system, and a draft NZ CS 1 content index already built in.

The legal risk architecture built into every sensitive framing decision reduces LPC’s exposure to the greenwashing risk faced by voluntary reporters under New Zealand’s fair dealing provisions. And the depth of physical risk disclosure showed authentic transparency: the draft Annual Report included approximately $5.7 million in actual climate-related financial impacts from FY26 storm events, which is exactly the kind of tangible, decision-useful disclosure the FMA’s 2026 Insights Report identifies as leading practice.

Whilst not all aspects of the wireframe recommendations could be integrated into the FY26 annual report, LPC has committed to iterative development that will see the content improved year-on-year to ensure that current guidance and expectations for credible, robust climate disclosures are incorporated.

For LPC’s stakeholders (investors, lenders, CCHL, Christchurch City Council, and the Canterbury community), the integrated Annual Report makes the port’s climate risk exposure and strategic response genuinely accessible. Not buried in an appendix that few readers find, but present in the sections of the report where it matters most.