Canada: CSA (Canadian Securities Administrators)

Draft climate disclosure rules for public companies, aligned with TCFD and ISSB.
Status: Final rules expected 2025-2026, phased for large issuers.

Companies Covered

3,500+

Canadian reporting issuers (2025 est.)

Frameworks

TCFD, ISSB

Draft rules harmonized with IFRS S1/S2[1]

Materiality

Financial

Disclosure if material to investors[1]

Scope 1, 2, 3 Emissions

1: Req, 2: Opt, 3: Vol

Scope 1 mandatory, Scope 2 optional, Scope 3 voluntary[1]

CSA Climate Disclosure Requirements (Draft)

Dimension	Description	Required?
Governance	Board oversight and management’s role in climate risk	Yes
Strategy	Material impacts of climate risks/opportunities on business/financials	Yes
Risk Management	Processes for identifying, assessing, managing climate risks	Yes
Metrics & Targets	GHG emissions (Scope 1 mandatory, 2 optional, 3 voluntary), climate targets if set	Partial

Canada Climate Disclosure Timeline

Year	Milestone	Status (2025)
2021	CSA proposes National Instrument 51-107 (TCFD-aligned)	Draft
2023	CSA announces ISSB-aligned revisions (IFRS S1/S2)	Consultation
2025	Final rules expected, phased for large issuers	Pending
2026	Phased implementation for all reporting issuers	Planned

Canada: Reporting Issuers by Sector (2025, est.)

Estimated number of Canadian reporting issuers by sector (2025).

CSA Integration and Influence

International alignment: TCFD, ISSB S1/S2, US SEC, EU CSRD[1]
Materiality: Financial materiality, not double materiality[1]
Phased implementation: Large issuers first, then all reporting issuers
Greenwashing risk: New guidance for ESG fund disclosures and marketing[1]
Cross-listing: Harmonization to avoid duplicative/conflicting requirements[1]

About Canada’s CSA Sustainability Disclosure Regime

The CSA coordinates climate and sustainability disclosure across Canada’s provinces and territories, with draft rules requiring TCFD- and ISSB-aligned reporting for all public companies[1]. The regime emphasizes financial materiality, phased adoption, and international alignment, with Scope 1 emissions mandatory, Scope 2 optional, and Scope 3 voluntary. Final rules are expected in 2025, with phased implementation through 2026, ensuring Canadian issuers remain globally competitive and transparent.

Note: All data reflects official CSA and industry updates as of May 2025.

Canada - CSA (Canadian Securities Administrators)

Canada - CSA (Canadian Securities Administrators)

Countries: Canada
Function: Draft rules mandating climate disclosures aligned with TCFD and ISSB

Visit CSA Website

Canada’s approach to sustainability disclosure is coordinated through the Canadian Securities Administrators (CSA), an umbrella organization representing provincial and territorial securities regulators across Canada’s fragmented regulatory system. The CSA plays a central role in harmonizing disclosure requirements nationally, ensuring consistency while allowing for regional jurisdictional authority.

In 2021, the CSA proposed National Instrument 51-107 – Disclosure of Climate-related Matters, aiming to introduce standardized climate-related disclosure obligations for Canadian reporting issuers. The proposed rules are explicitly aligned with the Task Force on Climate-related Financial Disclosures (TCFD), reflecting Canada’s commitment to international convergence on sustainability reporting practices.

Under the draft framework, publicly listed companies would be required to disclose:

Governance: The board’s oversight and management’s role in assessing and managing climate-related risks and opportunities.
Strategy: Material climate-related risks and opportunities and their actual and potential impacts on the issuer’s business, strategy, and financial planning.
Risk management: Processes for identifying, assessing, and managing climate-related risks.
Metrics and targets: Greenhouse gas (GHG) emissions data (Scope 1, Scope 2, and, optionally, Scope 3) and climate-related targets, if any have been set.

The CSA initially proposed mandatory Scope 1 disclosure, with Scope 2 optional and Scope 3 voluntary. However, after extensive public consultation and alignment with evolving global standards, particularly the ISSB’s IFRS S2 Climate-related Disclosures Standard, the CSA signaled adjustments toward tighter harmonization.

In October 2023, the CSA announced it would update its draft rules to better align with the ISSB standards, particularly IFRS S1 and S2, which integrate financial materiality with forward-looking sustainability risk disclosure. A finalized rule set is expected to be phased in beginning between late 2025 and 2026, with initial focus on large reporting issuers.

Key features of Canada's sustainability disclosure evolution include:

International alignment: The CSA has emphasized that Canadian issuers should not face duplicative or conflicting requirements relative to global peers, particularly given cross-listings on US and European exchanges.
Materiality-based disclosure: Following the financial materiality principle, disclosures will focus on information material to investor decision-making, similar to the US SEC approach rather than the EU’s double materiality standard.
Phased implementation: Transition periods and scaled requirements are expected, recognizing the varying preparedness of small and medium-sized issuers.

The CSA has published guidance on ESG-related investment fund disclosures and marketing practices, aiming to curb greenwashing risks and ensure transparency for retail and institutional investors.