In our submission to the Canadian Sustainability Standards Board (CSSB) consultation on proposed Canadian Sustainability Disclosure Standard (CSDS) 1 General Requirements for Disclosure of Sustainability-related Financial Information (CSDS 1) and CSDS 2 Climate-related Disclosures (CSDS 2), we make three recommendations:

1. The CSSB should fully adopt IFRS S1 and IFRS S2 in CSDS 1 and CSDS 2, with the only change being the effective date, January 2025 instead of January 2024.

2. The CSSB should not delay the requirement for Scope 3 emissions disclosure.

3. The CSSB should not delay the effective date for disclosures beyond climate-related risks and opportunities for two years.