Information Disclosure – technical frequently asked questions

These are intended to help clarify common areas of uncertainty, and help regulated suppliers navigate their reporting obligations. They will be updated from time to time as we get more questions.

These FAQs are intended to assist suppliers with complying with the information disclosure (ID) determination. However, to the extent this note differs from the determination, the determination prevails.

When do the information disclosure requirements apply?

We are phasing in the ID requirements through two mechanisms:

Timing for financial disclosures
- ‘Basic’ financial disclosure requirements will apply from the 2026-2027 reporting year.
- ‘Additional’ financial disclosure requirements will begin from the 2027-2028 reporting year.
- We may consider exemption requests for delayed disclosure beyond these dates on a case-by-case basis eg, where system constraints or upcoming system changes make implementation impractical.
Transitional period for asset management disclosures (27 February 2026 – 31 July 2030)

During the transitional period, regulated suppliers may choose one of two pathways for the requirements relating to the Strategic Asset Management Plan (SAMP), Asset Management Plan (AMP), Investment Delivery Plan (IDP) and Annual Delivery Report (ADR):

- Align with the enduring requirements – publish documents that fully meet the scope set out in Schedule C
- Transitional disclosures with a disclosure improvement plan – publish all information that suppliers currently hold that corresponds with the requirements (even if incomplete), noting whether each requirement is ‘met’, ‘partially met’ or ‘not met’. A disclosure improvement plan must also be included, outlining how the supplier will meet all requirements by 31 July 2030. Progress against the plan must be reported annually in the ADR

This framework enables suppliers to provide available information now while working toward full compliance with all enduring requirements by 31 July 2030.

When different information is due

The table below sets out when regulated suppliers are required to publish the specified information, including the frequency it should be published, and links to the determination clause reference.

Start date	Frequency	Requirements	Determination clause reference
2026
Immediate¹	When the requirement applies, disclose within 5, 10 or 30 working days	• Statement from existing minor aspect supplier and reasons why • Transfer agreement • Value of assets and liabilities transferred • Date of becoming or ceasing to be a regulated supplier • Date of taking over the drinking water supply of another provider	• Cls 4.11, 4.12, A12 • Cls 4.1, A10 • Cls 4.2, A10 • Cls 4.3, 4.4 • Cl 4.5
30 June	When the requirement applies, disclose immediately or within 10 working days	• Dividends policy • Policy for funding growth • Information about charges • Statement on becoming a minor aspect supplier	• Cls 4.6, A11 • Cls 4.7, A11 • Cls 4.8, A11 • Cls 4.11, 4.12, A12
2027
31 July²	On or before 31 July	• ‘Basic’ 10-year forecast financial information	• Cls 3.1, A2, A1
	Within 30 days of the date a water services strategy is adopted	• 30-year forecast capital expenditure • AMP • IDP • SAMP	• Cls 3.3, A4 • Cls 3.5, A5, A7 • Cls 3.6, A5, A8 • Cls 3.4, A5, A6
30 November	On or before 30 November	• ‘Basic’ previous financial year actual information (first disclosure under cl 3.2)	• Cls 3.2, A3, A1
2028
31 July	Annually, on or before 31 July	• ‘Full’ (basic and additional) 10-year forecast financial information	• Cls 3.1, A2
30 November ²	Annually, on or before 30 November	• ADR • ‘Full’ (basic and additional) previous financial year actual information	• Cls 3.7, A9 • Cls 3.2, A3

Wellington Water is not subject to immediate disclosure requirements because it continues to disclose information under Foundational Information Disclosure.
Transitional form of disclosure for ADR, AMP, IDP and SAMP disclosures before 1 July 2030.

What exemptions are available from the information disclosure requirements?

We recognise that, in limited circumstances, a regulated supplier may have good reasons why it is not able to fully meet specific information disclosure requirements.

Where appropriate, regulated suppliers may apply for an exemption from specific disclosure requirements. Exemptions will be considered on a case-by-case basis.

Situations where an exemption request may be appropriate include (but are not limited to):

Legislative constraints – where another piece of legislation restricts a supplier from collecting or disclosing certain information.
Timing constraints – where implementing the requirements would be impractical.

In assessing an exemption application, we consider:

why a supplier believes it cannot reasonably comply with the information disclosure requirements
any alternative disclosures proposed by the supplier
the extent to which the purpose of ID regulation would still be met including if any alternative disclosures are required or other conditions imposed.

However, we expect regulated suppliers to understand the importance of transparency and make every effort to collect and publish the required information where lawful to do so.

Exemption requests should be made as early as possible. An exemption cannot be granted retrospectively, so suppliers should apply before the relevant disclosure deadline where they consider they may be unable to meet a requirement.

What support will the Commission provide to help suppliers meet the new information disclosure requirements?

We will provide a range of support to help suppliers of regulated water services meet the new ID requirements. This includes:

Excel-based data templates to assist suppliers in presenting the required information
Webinars and drop-in sessions outlining the ID requirements
Direct engagement with individual regulated suppliers to answer questions and provide tailored guidance
Regularly updated FAQs to support consistent interpretation over time
Collaboration with the Office of the Auditor-General (OAG) on audit expectations and requirements

These tools and engagement activities will be rolled out over the next few months to support suppliers with system setup and smooth implementation. Subscribe to our updates to keep up to date with what’s going on at the Commerce Commission.

How do the disclosure requirements apply to multi-council water organisations with geographically differentiated services?

Geographic disaggregation means separating required information by geographic service area so that costs, performance, investment decisions, and revenues can be understood for each district individually.

Geographic disaggregation is required where a water organisation owned by multiple councils has different levels of charges or revenue recovery in different areas. Where differentiated charges apply, suppliers must clearly separate relevant disclosures by district area.

How are disclosures handled under split decision-making models?

A split decision-making model is where more than one entity collectively forms the regulated supplier, and each entity is responsible for different parts of the decision-making required to provide the regulated service.

Where regulated services are provided under a split decision-making model, each supplier involved must publish the required disclosures. However, if another regulated supplier in the model has already disclosed the required information, the remaining suppliers do not need to duplicate it. Instead, they must provide a link to where the information is published (eg, on the other supplier’s website).

What are the expectations for governance, assurance, and director or councillor sign off?

An assurance report signed by the auditor is required for certain ‘actual’ information disclosures (ie, not for forecast information).

For regulated suppliers that are local authorities, director certification of disclosures may be completed by either:

two members of the governing body of the local authority, or

one member of the governing body of the local authority and the Chief Executive.

This provides two permitted signoff options for meeting the certification requirements for regulated suppliers that are a local authority.

For other regulated suppliers (eg, water organisations), the certificate must be signed by two directors.

How should suppliers classify, report, and disclose financial information such as revenue, rates, charges, and income categories?

Regulated suppliers are required to disclose information on revenue (from charges or rates, and other sources) and other income in the categories defined in the ID determination. They must also disclose information about charges and levies (including any applicable IFF levies) that are payable to, or collected by, the regulated supplier.

What requirements apply to asset management planning and asset data reporting?

Regulated suppliers must prepare and disclose the following asset management documents:

Strategic Asset Management Plan

Asset Management Plan

Investment Delivery Plan

Annual Delivery Report

By 2030, these documents must meet the content requirements set out in Schedule C of the ID determination. The intention is to ensure regulated suppliers provide clear, structured, and transparent information on their asset management approach, performance and planned investments.

Transitional period (27 February 2026 – 31 July 2030)

During the transitional period, regulated suppliers may either:

publish the full suite of asset-management documents that meet Schedule C, or

publish transitional disclosures, including all currently held information that corresponds to the requirements (even if incomplete), identifying items as ‘met’, ‘partially met’, or ‘not met’, plus a disclosure improvement plan and annual progress reporting in the ADR. This sets clear expectations and supports capability-building across the sector while maintaining transparency.

Can suppliers include voluntary explanatory notes?

Yes. Suppliers may include explanatory notes to clarify assumptions, methods, or limitations. In some cases (eg, unit cost reporting), explanatory notes are required where information is unavailable, not applicable, or commercially sensitive.

What are the expectations for reporting innovation practices in asset management plans?

Innovation reporting should demonstrate how suppliers are trialling, developing, or applying new or improved technologies, processes, or approaches that improve outcomes for consumers. Disclosures should describe:

what innovation practices were undertaken, why they matter, and how they improve performance, resilience, efficiency, or customer experience

how innovation is embedded in broader asset management and continuous improvement frameworks.

The focus is on transparency and practical value rather than novelty for its own sake.

How should suppliers identify and report non-network assets in their asset management plans?

Suppliers should describe the types of non-network assets that support delivery of regulated services (eg, IT systems, vehicles, tools and equipment, office facilities, or consents) without listing every individual asset. Reporting should explain the role these asset types play, the policies, standards or procedures that apply to them, and any material maintenance, renewal or enhancement plans. Detail should be proportionate to significance.

Will the Commission provide templates for asset management planning and reporting documents?

No. Suppliers vary greatly in size, maturity and operating environment, so templates would not be practical. Instead, the determination sets out clear content requirements, while allowing suppliers to structure documents as they choose.

However, if industry groups consider there is value in developing templates, we would be happy to engage with that work led by others.

Are stormwater services regulated?

The economic regulation regime currently applies only to water supply and wastewater services.

Stormwater services are not subject to ID requirements at this stage, although there is flexibility for stormwater to be included at a later date if required.

However, suppliers may:

refer to stormwater where it is relevant to drinking water or wastewater disclosures (eg, shared technology or innovation projects)
publish required ID content within broader documents that also contain stormwater, provided required disclosures are clearly identifiable and not aggregated (eg, drinking water quantitative data must remain separate). As such, we expect that asset management planning documents may cover all three waters.

Do the information disclosure requirements override other information retention or release obligations?

No, the information disclosure requirements do not replace or override obligations under other legislation such as the Public Records Act 2005 or the Local Government Official Information and Meetings Act 1987. Suppliers must still comply with all other relevant obligations.

Is an apartment building with a single water meter classed as residential for disclosure purposes?

The ID determination sets out high-level definitions for customer and service categories, but it does not prescribe how every network or metering configuration must be classified. This includes arrangements such as apartment buildings with a single bulk water meter.

Where the determination is non-specific, suppliers should apply a reasonable and consistent approach that reflects how services are delivered, billed, and managed. Approaches may differ between suppliers but must be consistent and explainable.

What if a supplier does not have the level of detail required for forecast information?

Suppliers are expected to take a reasonable and proportionate approach to forecasting. This may include:

spreading quantities (eg, expenditure or revenue) across years or categories where appropriate
explaining key limitations, assumptions, or estimation methods in explanatory notes.

During transitional periods, transparency and continuous improvement are the priority. Forecasts should be prepared in good faith using the best information reasonably available, rather than delaying disclosure in pursuit of precision that is not yet achievable.

How is the term ‘related party’ used for information disclosure purposes?

For ID purposes, the term ‘related party’ is broader than it is under GAAP. In addition to third parties, a related party can include another part of the council or water organisation that supplies unregulated services.

This means some transactions within a single council or organisation may be considered related party transactions, for ID purposes. Some council examples include:

the payment of property rates to the council in respect of buildings used for regulated water services
internal recharges under shared-service agreements from other parts of the council (for example for IT, finance, or other business support services provided to the part of council providing regulated water services)
the supply of services to other parts of council that provide unregulated activities.