CA ANZ welcomes the opportunity to provide a submission to the Climate Change Commission’s recent consultation. CA ANZ has consistently been an advocate for, and supporter of, a just transition to a low-emissions economy. The accounting profession can make a significant contribution to both climate change mitigation and adaptation at individual entity, industry sector and economy-wide levels.

Our key points are outlined below:

• We recommend the Commission specifically considers the role that businesses can play in supporting this transition and the importance of a genuine, active and enduring partnership between the public and private sectors.
• Policies that foster innovation are essential to New Zealand’s transition to a low-emissions economy and recommendations to assist Government in developing such policies would be beneficial. 
• The role of the tax system in supporting the just transition should be acknowledged, and the current incentives offered by the tax system should be assessed against the criteria developed by the Government’s Tax Working Group. The future tax base may be impacted by policies that result from the Commission’s recommendations, resulting in changes in behaviour that could lead to redistribution of tax revenues from various sources. 
• We agree that the earlier change is made, and good policies are implemented, the more effective efforts will be in reducing emissions over the full period to 2050. We urge robust post-implementation reviews of each policy. 
• We suggest that the recommendations are listed and grouped in the order of priority and level of impact as this may assist with the Government’s decisions. 
• Part three of the report, ‘enabling system transformation’, does not include any recommendations. In our view, adding relevant recommendations would be beneficial. 
• Required changes in the agricultural sector may be cost prohibitive for some farmers and these individuals, their suppliers, service providers and communities will need to be supported throughout this transition.

CA ANZ responded to the Commission’s consultation on the draft advice for the Government’s first emissions reduction plan in 2021, which is also available on our website.