Sustainability reporting updates
In recent years, there have been critical global and national developments in sustainability reporting, including the creation of the International Sustainability Standards Board (ISSB) under the International Financial Reporting Standards (IFRS) Foundation.
WHY IS THIS RELEVANT FOR CANADA?
An increasing number of entities reporting within Canada provide information on their sustainability performance. As reporting increases and momentum continues toward a global sustainability reporting system, Canadian entities must be familiar with the changing sustainability reporting landscape.
CPAs will need to understand the reporting requirements and be capable of identifying risks and opportunities that exist for their organizations and clients.
Outlined below are key updates from the profession, standard setters and regulators, which will provide you with an understanding of the ongoing developments. Additionally, CPA Canada’s comment letters on recent sustainability standards and regulatory proposals can be found here.
This page captures developments as of October 22, 2024.
Standard setting
The Independent Review Committee on Standard Setting in Canada (IRCSS) and the Canadian Sustainability Standards Board (CSSB)
As part of the IRCSS’ recommendations, the CSSB was formally announced in June 2022. The CSSB develops Canadian Sustainability Disclosure Standards (CSDS) that align with the global baseline standards developed by the ISSB – but with modifications to serve the Canadian public interest. The CSSB’s December 2022 appointment to the Sustainability Standards Advisory Forum will support mutual objectives. A significant milestone was reached in March 2024 with the CSSB issuing for public comment its first two CSDS, as well as a Consultation Paper on a Proposed Criteria for Modification Framework. The proposed CSDS align with IFRS S1 and IFRS S2, with modifications to suit the Canadian public interest. The comment period for these consultations closed on June 10, 2024, and the CSSB published a Feedback Statement in October 2024. Following consideration of the feedback received, the CSSB expects to issue final standards later this year. For more information, you can visit: Canadian Sustainability Standards Board.
Updates on the IRCSS in Canada can be accessed on their website.
ISSB updates on developments toward global sustainability standards
On June 26, 2023, the ISSB issued its first two IFRS Sustainability Disclosure Standards:
- IFRS S1: General Requirements for Disclosure of Sustainability-Related Financial Information (IFRS S1)
- IFRS S2: Climate-related Disclosures (IFRS S2)
For responses to frequently asked questions about the IFRS Sustainability Disclosure Standards, their adoption in Canada and related assurance requirements, CPA Canada has prepared this FAQ that was published on June 26, 2023. A roadmap of activity leading up to the release of these two standards and next steps can be found here.
Please refer the IFRS Foundation’s project summary document for an overview of the requirements in these Standards. Please refer to the ISSB webpage for comprehensive information.
ISSB Consultation on Agenda Priorities
On May 4, 2023, the ISSB published the Request for Information Consultation on Agenda Priorities to seek feedback on its priorities for its next two-year work plan. Based on research into the information needs of investors, the ISSB sought feedback on potential research projects focused on:
- sustainability-related risks and opportunities associated with
- biodiversity, ecosystems and ecosystem services
- human capital
- human rights
- how to integrate information in financial reporting beyond the requirements related to connected information in IFRS S1 and IFRS S2
Having considered the feedback received and its own capacity, the ISSB has decided to add to its work plan research projects on the risks and opportunities associated with (1) biodiversity, ecosystems and ecosystem services; and (2) human capital. For further information, refer to the ISSB’s Feedback Statement published in June 2023.
ISSB Exposure Draft on Sustainability Accounting Standards Board (SASB) Standards
On May 11, 2023, the ISSB published for comment an Exposure Draft of Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates. The comment period is now closed.
Information on the ISSB, including meeting agendas and papers can be found on its website.
EU sustainability standards
On December 16, 2022, the final text of the Corporate Sustainability Reporting Directive (CSRD) was published in the Official Journal of the European Union. The CSRD extends to large and listed EU companies. Additionally non-EU entities having at least one subsidiary or branch in the EU and generating net turnover of EUR 150 million in the EU will be subject to the sustainability reporting requirements. On January 5, 2023, the CSRD entered into force. The reporting requirements will be phased in over time for different kinds of companies with the first set of companies being required to apply the standards in financial year 2024, for reports published in 2025.
The final CSRD confirmed the role of the European Financial Reporting Advisory Group (EFRAG) as the technical advisor to the European Commission developing draft European Sustainability Reporting Standards (ESRS) along with their basis for conclusion, cost-benefit analysis and guidance for Digital Reporting. The CSRD requires in-scope companies to report on sustainability-related issues based on detailed disclosure standards developed by EFRAG.
REGULATORY
Canada
In October 2022, the Canadian Securities Administrators (CSA) announced that it is actively considering the impact of international developments and how they may impact or further inform the proposed climate-related disclosure rule which was published in October 2021. More recently, in a March 2024 news release, the CSA welcomed the launch of the CSDS and indicated that once the CSSB consultation is complete and its standards are finalized, the CSA anticipates seeking comment on a revised rule setting out climate-related disclosure requirements.
In a recent Staff Notice on its continuous disclosure review program activities for the years ended March 31, 2022 and 2021, CSA staff indicated that they have observed an increase in “greenwashing” in continuous disclosure documents as well as voluntary documents, such as sustainability or ESG reports and public surveys. CSA staff note that when describing current and proposed ESG related activities, issuers should avoid using misleading promotional language. Further, the staff notice highlights that statements regarding carbon neutrality will generally constitute forward-looking information (FLI). The issuer must have a reasonable basis for the FLI, identify the material risks factors that could cause actual results to differ materially, state the material factors or assumptions used to develop the FLI and describe its policies for updating the information.
In April 2023, the CSA announced that it is seeking public comment on proposed amendments to corporate governance disclosure rules and policy relating to the director nomination process, board renewal and diversity. The proposed amendments would require disclosure on aspects of diversity beyond the representation of women, while retaining the current disclosure requirements with respect to women. The comment period is now closed.
In March 2023, the Office of the Superintendent of Financial Institutions Canada (OSFI) issued Guideline B-15 which sets out OSFI’s expectations for the sound management of climate-related risks for federally regulated financial institutions (FRFIs). The OSFI guideline will be effective fiscal year-end 2024 for Domestic Systemically Important Banks and Internationally Active Insurance Groups headquartered in Canada, and fiscal year-end 2025 for all other in-scope FRFIs. In March 2024, OSFI released updates to Guideline B-15, which ensure that the expectations for FRFIs in the Guideline’s Annex 2-2 align with the IFRS S2. Also, in October 2023, OSFI released its draft Standardized Climate Scenario Exercise (SCSE) methodology for consultation, for which the comment period is now closed.
In July 2024, the Autorité des marchés financiers (AMF) published its Climate Risk Management Guideline, following public consultation that began in November 2023. The guideline came into effect upon publication; however, the timing of the requirements varies depending, for example, on the type of organization and type of disclosure. The AMF indicates in the guideline that it is focusing on strengthening the resilience of the financial sector and the financial institutions it regulates.
In June 2024, new amendments to the Competition Act became law following Royal Assent of Bill C- 59. The amendments include adding two paragraphs which require that companies be able to substantiate environmental claims made to promote a product or business interest. In a statement issued on July 4, 2024, the Competition Bureau (the Bureau) indicated that it has received a large number of requests for guidance on the interpretation of these new provisions aimed at greenwashing. On July 22, 2024, the Bureau launched a public consultation on these new provisions that will inform its future enforcement guidance about environmental claims. The consultation period closes on September 27, 2024. This Guide to the June 2024 amendments to the Competition Act has also been published in the interim.
In October 2024, the Federal government made two significant announcements related to advancing sustainability-related finance and reporting: (1) it is supporting the development of voluntary “Made-in-Canada” sustainable investment guidelines (i.e., taxonomy), which will include both “green” and “transition” investment categories, and (2) it intends to amend the Canadian Business Corporations Act to mandate climate-related financial disclosures for large, federally incorporated private companies. Read the October 9, 2024, news release and Backgrounder for further information.
United States
In March 2024, the Securities and Exchange Commission (SEC) adopted final rules for the Enhancement and Standardization of Climate-Related Disclosures for Investors. The rules will require information about a registrant’s climate-related risks that have materially impacted or are reasonably likely to have a material impact on, its business strategy, results of operations, or financial condition, as well as reporting of Scope 1 and Scope 2 greenhouse gas (GHG) emissions by large accelerated filers and accelerated filers. In addition, certain disclosures related to severe weather events and other natural conditions will be required in the notes to the audited financial statements. The reporting requirements will be phased in over time with the compliance dates depending on the type of disclosures and type of registrant. For example, large accelerated filers will be expected to start providing certain disclosures for fiscal years beginning in 2025. There will also be independent assurance requirements for GHG emissions disclosure for large accelerated filers and accelerated filers. The final rules cover both domestic public companies and foreign private issuers, other than Multijurisdictional Disclosure System (MJDS) filers. The MJDS allows certain Canadian issuers to register their securities with the SEC, and use documents prepared largely in accordance with Canadian requirements.
Further information on the final rule can be found in the SEC’s Fact Sheet.
Public Sector
In December 2022, the International Public Sector Accounting Standards Board (IPSASB) confirmed its role in advancing public sector sustainability reporting. It has decided to begin the scoping of three potential public sector specific sustainability reporting projects pending securing the resources needed to begin guidance development. The prioritized research topics for these projects are:
- general requirement for sustainability-related financial disclosure;
- climate-related disclosures;
- natural resources – non-financial disclosures (in parallel with the development of financial reporting guidance proposed in its Consultation Paper, Natural Resources).
Following the scoping and research phase, the IPSASB decided to move forward with the development of a public sector specific Climate Related Disclosures standard at its June 2023 meeting and has published a Climate-Related Disclosures project brief.
In October 2023, IPSASB opened a consultation to hear stakeholder feedback on its proposed strategy and work program for the next five years (2024-2028). Following consultation, the IPSASB Strategy and Work Program 2024-2028 was issued in October 2024.
ASSURANCE ON SUSTAINABILITY REPORTING
Please visit CPA Canada’s Sustainability assurance resources webpage.