Policy Recommendations
We make informed policy recommendations to regulators and other institutions at the provincial and federal levels. Here is a list of our submissions to policymakers.
Submission on CAPSA Guideline for Pension Plan Risk Management for Plan Administrators
The Canada Climate Law Initiative appreciates the ambitious nature of the Canadian Association of Pension Supervisory Authorities (CAPSA) Guideline for Pension Plan Risk Management for Plan Administrators, covering foundational pension risk management concepts, including environmental, social, and governance (ESG) considerations, leverage, cybersecurity, investment risk, and use of third parties, all of which are currently priorities […]
Read moreSubmission to Office of the Superintendent of Financial Institutions (OSFI) for its draft Guideline B-15 Climate Risk Management
The Canada Climate Law Initiative (CCLI) applauds the Office of the Superintendent of Financial Institutions (OSFI) for its draft Guideline B-15 Climate Risk Management. The proposed Guideline is important recognition that climate-related risks can significantly affect the safety and soundness of federally-regulated financial institutions (FRFI), in turn affecting the integrity of the Canadian financial system. […]
Read moreSubmission on CAPSA’s draft Guideline on Environmental, Social and Governance Considerations in Pension Plan Management (ESG Guideline)
We are thankful for the opportunity to make submissions on the Canadian Association of Pension Supervisory Authorities’ (CAPSA‘s) draft Guideline on Environmental, Social and Governance Considerations in Pension Plan Management (ESG Guideline). The Canada Climate Law Initiative (CCLI) supports the three very broad principles contained in the Guideline; however, our view is that the baseline […]
Read moreSubmission to IFRS ISSB on IFRS S2 Climate-related Disclosures
The International Financial Reporting Standards Foundation (IFRS) and its International Sustainability Standards Board (ISSB) provided the opportunity to comment on the proposed IFRS S2 Climate-related Disclosures (IFRS S2). The Canada Climate Law Initiative (CCLI) supports the overall framework of the exposure draft being aligned with the Financial Stability Board’s (FSB) Taskforce on Climate-related Financial Disclosures […]
Read moreSummary of Submissions to Canadian Securities Administrators on Proposed National Instrument 51-107 Disclosure of Climate-related Matters
The Canadian Securities Administrators (CSA) received 131 submissions on proposed National Instrument 51-107 Disclosure of Climate-related Matters (NI 51-107) during the four-month public consultation period, of which 94% were from organizations and 6% were from individuals. We published a summary of the 131 submissions. This is a Canada Climate Law Initiative publication.
Read moreConsultation on Climate-related Risks in the Financial Sector
In January 2021, the Office of the Superintendent of Financial Institutions (OSFI) launched a three-month consultation with the publication of a discussion paper, Navigating Uncertainty in Climate Change: Promoting Preparedness and Resilience to Climate-Related Risks. The paper focuses on risks arising from climate change that can affect the safety and soundness of federally regulated financial institutions (FRFIs) […]
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