June 3, 2022

A New Dawn in Climate Disclosure: Comparing Canada’s proposed National Instrument 51-107 with proposed SEC rules and IFRS/ISSB standards

Policies on disclosure of climate-related risks and opportunities are rapidly developing in Canada and globally.  The Canada Climate Law Initiative (CCLI) has produced this chart to allow policymakers, investors, and civil society organizations to compare proposals made by Canadian securities regulators in proposed National Instrument 51-107 Disclosure of Climate-related Matters, with the United States Securities and Exchange Commission (SEC) Proposed Rules on the Enhancement and Standardization of Climate-Related Disclosures for Investors, and the International Financial Reporting Standards (IFRS) Foundation’s new International Sustainability Standards Board’s Exposure Draft IFRS S2 Climate-Related Disclosures. Please note that the SEC rule is over 500 pages and CCLI has highlighted proposed requirements using the Taskforce on Climate-related Financial Disclosures (TCFD) framework to organize the comparisons made in the chart. Readers are advised to consult the actual proposed rules and standards for more detailed information.

None of the proposed national instrument/rules/exposure draft are yet finalized. The Canadian Securities Administrators’ consultation period on proposed NI 51-107 is complete, and a summary of the 131 submissions can be found at Summary of 131 submissions to CSA on proposed National Instrument 51-107 Disclosure of Climate-related Matters – Canada Climate Law Initiative (ubc.ca). There is currently a public consultation period for the proposed SEC rule, which ends 17 June 2022. For the IFRS/ISSB exposure draft, the public consultation period ends 29 July 2022.

This is a Canada Climate Law Initiative publication.