Download PDF:

CSSB – Consultation Paper on Canadian Sustainability Disclosure Standards (CSDS)

Letter Summary:

The Canadian Sustainability Standards Board (CSSB) is requesting feedback on its first proposed Canadian Sustainability Disclosure Standards (CSDS), marking a significant milestone in advancing sustainability reporting in Canada.

The proposed standards aim to set a new benchmark for the disclosure of sustainability-related information, facilitating a more consistent and comparable approach.

The International Sustainability Standards Board (ISSB) issued its first standards in June 2023 – IFRS S1, General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2, Climate-related Disclosures.

Committed to the global baseline the ISSB established, the CSSB’s proposed CSDS 1 and CSDS 2 align with IFRS S1 and S2 – but with Canadian-specific modifications suggested. Also available for public comment is a paper discussing how the CSSB proposes to introduce changes, if required, to IFRS Sustainability Disclosure Standards for use in Canada.

Proposed modifications to CSDS 1 and CSDS 2 include Canadian-specific effective dates and transition relief proposals to help with eventual implementation of the standards.

Overview of the Council’s Comments:

 In general, the CAC believes that any changes to the IFRS Sustainability Disclosure Standards should be additive and not subtractive from the established international baseline, i.e. the IFRS Sustainability Disclosure Standards should not be diluted. CSSB should look to add additional standards and requirements where required, but should not delete requirements from the IFRS Sustainability Disclosure Standards in creating Canadian standards.

The CAC also cautioned against any further delays of the standards’ effective date, noting that these are voluntary standards until made mandatory by legislation and regulation, and should support those Canadian issuers that are ready and wish to lead in the timing of sustainability disclosures consistent with the IFRS Sustainability Disclosure Standards.