Submission to Finance Canada as part of its Pre-budget Consultations in advance of the upcoming 2026 Fall Federal Budget

Prime Minister Carney has called for “climate policy that is unifying, credible, and predictable; that reduces emissions, drives investment, and builds the economy of the future.” Our recommendations to Finance Canada in advance of the 2026 federal budget can amplify federal action on climate-related financial risks and opportunities:

Recommendation 1: Amend Canada Business Corporations Act (CBCA) Regulation, 2001 SOR/2001-512 to include a new sub-section: “s.72(3). The financial statements shall include a business resilience plan to reach net-zero greenhouse gas 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.”

Recommendation 2: Amend section 7.1 of the Pension Benefits Standards Regulations, 1985 SOR/87-19 to require that federally-regulated pension plan (FRPP) administrators, under their current obligations to establish a written statement of investment policies and procedures, adopt business resilience plans and determine how their climate resilience policies pertain to the plan’s portfolio of investments and loans.