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.

1. Wellington Water is not subject to immediate disclosure requirements because it continues to disclose information under Foundational Information Disclosure.

2. 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 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.

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. 

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.

Will the Commission expect unit costs to differ across the country, especially in areas of challenging terrain?

The Commission expects that unit costs will differ across the country, for example due to more or less challenging terrain. The information that regulated suppliers provide in support of the unit cost data, like the assumptions and approach (under clause 5.19(6) of the determination) will support stakeholders to understand the drivers of differences in unit costs.

If different regulated suppliers take different approaches to what scope of works should be included, the sector may wish to work together on a standardised approach.

How will the Commission assess capital expenditure adequacy when different councils and water organisations can use different GAAP depreciation and revaluation approaches?

We consider that the use of metrics and ratios based on expenditure, depreciation, and asset values is only an initial starting point for analysis of capex adequacy. Differences in approach to calculation of items like depreciation can further exacerbate the issues with capex adequacy ratios.

Stakeholders will be able to garner a much richer understanding of capex adequacy from the full suite of information disclosures—particularly the asset management planning documents and the breakdown of capital expenditure into standardised categories by apportionment.

Does the geographic disaggregation requirement mean all financial information must be split by district?

Yes. Disclosure of financial information (such as expenditure) must be disaggregated by district if a regulated supplier differs its pricing geographically. The full description of what is required to be disaggregated and what is not is provided in clause 2.4 of the determination.

Is there guidance on what ‘good’ looks like for SAMPs and AMPs?

There is no single exemplar sector to point to. Frameworks such as ISO 55000 and guidance from industry bodies like Āpōpō can be helpful, but good practice will depend on what works for each provider’s business. The asset management planning documents should be appropriate to the scale and risk of a regulated supplier, so those from Watercare should look quite different to those from Wairoa District’s water organisation.

If income and expenses are tracked by scheme, do we report at scheme level or district level?

Reporting is required at the district level if district level reporting is required under clause 2.4 of the determination, or at the level of the whole regulated service if not. So, reporting is not required at the scheme level. However, some aspects of the asset management planning documents will likely discuss elements that are specific to certain schemes, such as a specific asset replacement programme.

Do regulated suppliers need to report variance of expenditure against forecast in the first year of reporting?

The first year of reporting actual expenditure will occur for a year that did not have a corresponding expenditure forecast required under clause 3.1 of our information disclosure requirements determination. So, reporting of variances is not required in the first year.

Do regulated suppliers need to report actual expenditure on material projects and programmes in the first year of reporting?

No. Regulated suppliers are only required to report expenditure on material projects and programmes that are specified in the investment and delivery plan. Because suppliers will not have published asset management documents under ID for the 2026/27 year, there are no “specified material projects and programmes” to report on for 2026/27.

Is the data for 'combined services' simply the sum of the data for 'water supply services' and 'wastewater services'?

For some regulated suppliers, the combined services value may simply be the sum of the values for each of water supply services and wastewater services. We understand though that in some instances, inter-service adjustments may be required to get to the combined services value.

In the reporting templates that we have prepared for financial ID information, we have generally included a sum function for the ‘combined services’ values. However, regulated suppliers can override this and instead manually enter a value if this calculation is not appropriate for them.

For councils that are not forming their water organisation until 1 July 2027 (for 2027/28 financial year), do they still need to disclose in the first year (actuals for 2026/27 financial year)?

Yes. Councils that are not forming their water organisation until 1 July 2027 are still subject to the ID requirements and are therefore required to disclose actuals for the 2026/27 financial year, provided they are a regulated supplier.

We acknowledge, however, that this may involve a significant amount of work especially for only one year of disclosures. In recognition of this, councils have been advised to:

• Carefully review the determination to understand which disclosure requirements apply in the first year.
• Assess what can reasonably be complied with in 2026/27 and identify areas where full compliance may be difficult.
• Consider transitional processes, such as data mapping, that can be used while services remain with Councils, instead of undertaking systemic coding changes.
• Explore the exemption framework, where certain disclosure requirements may be particularly difficult to meet, and consider applying for an exemption from specific disclosure requirements, where appropriate.