The International Financial Reporting Standards Foundation (IFRS) and its International Sustainability Standards Board (ISSB) provided the opportunity to comment on the exposure draft proposing amendments to IFRS S2 Climate-related Disclosures. The amendments would provide reliefs to ease application of requirements related to the disclosure of greenhouse gas (GHG) emissions.

The Canada Climate Law Initiative (CCLI) commends the ISSB’s leadership in advancing high-quality, globally aligned sustainability disclosure standards and appreciates its commitment to fostering transparency, accessibility, and consistency in the sustainability reporting landscape. It is our view that the disclosure of derivatives, facilitated, and insured-associated emissions remains critical to understanding climate-related financial risks. The removal of these disclosures raises several concerns. We have organized our submission to answer the questions specifically posed in the Exposure Draft and offer a number of suggestions.