August 21, 2025

Submission to Finance Canada as part of its Pre-budget Consultations in Advance of the upcoming 2025 Fall Federal Budget


In alignment with Prime Minister Carney’s call to have “a climate policy that is unifying, credible, and predictable; that reduces emissions, drives investment, and builds the economy of the future”, the following recommendations can amplify federal action in attracting capital towards sustainable economic activities and strengthening Canada’s economy by enhancing the management of climate-related financial risks and opportunities and increasing our competitiveness and resiliency:


1:  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.”
 
2:  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 benchmarking climate risk management.
 
3:   Amend section 7.1 of the Pension Benefits Standards Regulations to require that federally-regulated pension plan (FRPP) administrators, under their current obligations to establish a written statement of investment policies and procedures (SIPP), adopt transition plans and determine how their climate resilience policies (mitigation and adaptation) pertain to the plan’s portfolio of investments and loans.