CSA NI 51-107 Climate Related Disclosure

January 31, 2022

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CSA NI 51-107 Climate Related Disclosure

Letter Summary:

There are a number of other sustainability and ESG-related disclosure topics that should be prioritized for the future, many of which will vary depending on investor needs and the materiality of these issues in their impact on various issuer sectors and different regions. Within these topics, we would include consideration of the unique and urgent demands of Indigenous reconciliation, as well as consideration of requiring wider sustainability-related disclosure consistent with the SASB Standards (now maintained as part of the Value Reporting Foundation). We would also suggest some consideration of issues contemplated by other reporting frameworks and standards such as the GRI Standards that highlight the double materiality of ESG issues to an issuer, net-zero emissions requirements as well as social and governance factors in this list.

Overview of the Council’s Comments:

The CSA strongly supports the efforts to further develop issuer disclosure of climate-related matters in Canada. While it may be somewhat incrementally costly for issuers to be mandated to provide Scope 1 and Scope 2 emissions information, the global commitments that have been made by governments and coalitions of both issuers and investors will require such information to be provided in the near term. It is important that any such information be provided using standardized methodologies and formats for comparability and consistency. We also look forward to participating in future consultations involving other sustainability and ESG-related matters as disclosure on climate-related matters is but one piece of the puzzle.