The Financial Markets Conduct Act 2013 (FMCA) amended in 2021, requires that Climate Reporting Entities (CREs), specified by a threshold of capital or assets, report their climate-related risks using a set of standards developed by the External Reporting Board (XRB).
In order for CREs to take the most benefit from the new requirement, it should be considered as more than just a compliance exercise. In that sense, it is quite similar to conduct risk and associated remediation: the disclosure may lead to structural changes and transform the way a CRE considers its future.
"Perfect is the enemy of done" – because of the complexity brought by the disclosure requirements, it may be preferable to start early and small, and grow in maturity in the subsequent iterations.