Policy Recommendations

We make informed policy recommendations to regulators and other institutions at the provincial and federal levels. Here is a list of our submissions to policymakers.

Feb 21st, 2023

Submission to federal Ministers Champagne and Guilbeault on Amendments to CBCA Regulation

The Canada Climate Law Initiative (CCLI) proposes amending the regulations pursuant to the Canada Business Corporations Act Regulations to promote the management of climate-related financial risk and opportunities in a vital portion of the economy and lead to a more resilient economy. The CCLI proposes a new subsection under s. 72 of the Canada Business […]

Read more
Sep 29th, 2022

Submission to Office of the Superintendent of Financial Institutions (OSFI) for its draft Guideline B-15 Climate Risk Management

The Canada Climate Law Initiative (CCLI) applauds the Office of the Superintendent of Financial Institutions (OSFI) for its draft Guideline B-15 Climate Risk Management. The proposed Guideline is important recognition that climate-related risks can significantly affect the safety and soundness of federally-regulated financial institutions (FRFI), in turn affecting the integrity of the Canadian financial system. […]

Read more
Sep 20th, 2022

Submission on CAPSA’s draft Guideline on Environmental, Social and Governance Considerations in Pension Plan Management (ESG Guideline)

We are thankful for the opportunity to make submissions on the Canadian Association of Pension Supervisory Authorities’ (CAPSA‘s) draft Guideline on Environmental, Social and Governance Considerations in Pension Plan Management (ESG Guideline). The Canada Climate Law Initiative (CCLI) supports the three very broad principles contained in the Guideline; however, our view is that the baseline […]

Read more
Aug 8th, 2022

Submission to IFRS ISSB on IFRS S2 Climate-related Disclosures

The International Financial Reporting Standards Foundation (IFRS) and its International Sustainability Standards Board (ISSB) provided the opportunity to comment on the proposed IFRS S2 Climate-related Disclosures (IFRS S2). The Canada Climate Law Initiative (CCLI) supports the overall framework of the exposure draft being aligned with the Financial Stability Board’s (FSB) Taskforce on Climate-related Financial Disclosures […]

Read more
Mar 30th, 2022

Summary of Submissions to Canadian Securities Administrators on Proposed National Instrument 51-107 Disclosure of Climate-related Matters

The Canadian Securities Administrators (CSA) received 131 submissions on proposed National Instrument 51-107 Disclosure of Climate-related Matters (NI 51-107) during the four-month public consultation period, of which 94% were from organizations and 6% were from individuals. We published a summary of the 131 submissions. This is a Canada Climate Law Initiative publication.

Read more
Jan 17th, 2022

Submission to the CSA on Proposed NI 51-107 Disclosure of Climate-related Matters

Our organization supports proposed National Instrument 51-107 Disclosure of Climate-related Matters (NI 51-107) and its alignment with the recommendations of the Taskforce on Climate-related Financial Disclosures (TCFD). We encourage the CSA to implement mandatory disclosure of climate-related risks and opportunities as soon as possible. Our recommendations will enhance the achievement of the CSA’s objectives and […]

Read more