Policy Recommendations

We mobilize our network of Principal Co-Investigators, Climate Governance Experts, Affiliated Research Scholars, and partners to make informed policy recommendations to regulators and other institutions at the provincial and federal levels.

Submission on 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 it sets by including only three principles is too low and not in alignment with regulatory developments internationally. CCLI believes that pension climate governance should have specific requirements, as we discuss in our letter to CAPSA.

Submission 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).

Consultation on Disclosure of Climate-related Matters

In October 2021, the Canadian Securities Administrators proposed a National Instrument 51-107 Disclosure of Climate-related Matters and its companion policy. The Proposed Instrument would introduce disclosure requirements regarding climate-related matters for reporting issuers (other than investment funds). We submitted a letter of policy recommendations in January 2022.

Consultation 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) and federally regulated pension plans (FRPPs). We submitted a letter of policy recommendations in April 2021.

Consultation on Bill C-97

The Innovation, Science, and Economic Development Canada opened a consultation on the amendments to the Canada Business Corporations Act (CBCA) to bring transparency and more effective governance to federally-regulated companies. We submitted a letter of policy recommendations in March 2021.

Consultation on Strengthening Canadians’ Retirement Security

The Financial Sector Policy Branch, Department of Finance Canada opened a public consultation on Canadian’s pension plans to support the sustainability of and strengthen the framework for federally regulated private pension plans. We submitted a letter of policy recommendations in January 2021.

Time to Act

The Expert Panel on Sustainable Finance has been commissioned by the Canadian Government to determine how best to generate sustainable finance, a significant challenge given the carbon intensity of Canada’s economy. The Expert Panel has defined sustainable finance as capital flows, risk management activities and financial processes that assimilate environmental and social factors as a means of promoting sustainable economic growth and the long-term stability of the financial system. Our report offers a comprehensive set of recommendations on these fiduciary obligation and ESG disclosure.