March 10, 2025
Submission to Finance Canada: Pre-budget consultations in advance of the 2025 spring federal budget
Pre-budget consultations are an opportunity for Canadians from across the country to contribute to shaping the Government of Canada’s policies and priorities for Canada’s future.
The Canada Climate Law Initiative submitted recommendations to Finance Canada regarding priorities for the spring 2025 federal budget. We make three suggestions to improve federal management of climate-related financial risks and opportunities, and to help achieve a sustainable economy for all Canadians:
- Amend Canada Business Corporations Act Regulation SOR/2001-512 to include a new sub-section: “s.72(3). The financial statements shall include a climate transition plan to reach net-zero greenhouse gas (GHG) emissions no later than 2050, with 5-year targets for emissions reductions towards the net-zero target, including disclosure of Scope 1, 2, and 3 emissions and annual reporting of progress towards meeting targets.”
- Approve and implement the third-party organizations required to develop, implement, and maintain the Canadian green and transition finance taxonomy. The taxonomy is an essential part of Canada’s transition to sustainable finance and should be instituted promptly to set standards for classifying climate-related financial instruments and bench-marking climate risk management.
- Amend Pension Benefits Standards Regulations to require that pension plans adopt transition plans and reconcile their climate-related policies with their investment portfolios. Section 7.1 should be amended to require that federally-regulated pension plan (FRPP) administrators, under their current obligations to establish a written statement of investment policies and procedures (SIPP), determine how their climate resilience policies (mitigation and adaptation) pertain to the plan’s portiolio of investments and loans.