In March 2024, the CSSB published its proposals for the first Canadian Sustainability Disclosure Standards (CSDSs) based on IFRS S1 and IFRS S2, albeit with exemptions. Ten major Canadian pension funds have now responded with a joint statement.
The statement notes that global adoption of the ISSB standards as proposed is the “only credible route to secure the ISSB’s equivalence with the European Sustainability Reporting Standards (ESRS):
“Failure to adopt the global baseline in Canada may not only risk issuers falling short of meeting international and domestic investors’ expectations of their directors to oversee corporate strategy in the near-term, but also risk issuers having to adopt Canada’s final standards and European reporting standards, which could be more onerous for issuers over time.”
In particular, the pension funds take issue with the CSSB’s sustainability-related disclosures transition relief, which, they argue, might put Canadian companies at a disadvantage to foreign entities that are reporting across all sustainability-related metrics. On the transition reliefs proposed for the climate standard, the pension funds query the suggested two-year reporting exemption for Scope 3 disclosures and the CSSB’s suggestion for exemptions on conducting scenario analysis.
The statement notes that the pension funds "support the ISSB’s “building block” approach, which allows for additions to the global baseline and limits modifications or deletions." It continues to say:
“Therefore, we recommend that the CSSB consider only additions to the ISSB baseline when unique circumstances arise in the Canadian public interest, such as addressing the rights of Indigenous Peoples. We believe this approach would best serve the ISSB’s objective of achieving interoperability across jurisdictions.”
Access the statement on the CSSB’s website.