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.

Nov 22nd, 2023

Submission to Alberta Government on Strengthening Climate Resilience in the Financial Services Sector

The Canada Climate Law Initiative submits that three key policy recommendations have the potential to considerably enhance the Alberta government’s oversight of financial services.

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Sep 29th, 2023

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 […]

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Feb 21st, 2023

Submission to federal Ministers Champagne and Guilbeault on Amendments to CBCA Regulation

The Canada Climate Law Initiative (CCLI) proposes amending the regulations pursuant to the Canada Business Corporations Act Regulations to promote the management of climate-related financial risk and opportunities in a vital portion of the economy and lead to a more resilient economy. The CCLI proposes a new subsection under s. 72 of the Canada Business […]

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Sep 29th, 2022

Submission 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. […]

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Sep 20th, 2022

Submission 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 […]

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Aug 8th, 2022

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). 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 […]

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