This policy applies to business that meet the following criteria.

Region

Canada

Industries

Agriculture, Forestry, and Fishing|||Agribusiness|||Construction and Real Estate|||Education and Research|||Energy and Utilities|||Financial Services|||Healthcare and Pharmaceuticals|||Hospitality and Tourism|||Legal and Professional Services|||Manufacturing|||Public Sector and Non-Profits|||Retail and Consumer Goods|||Technology and Telecommunications|||Transportation and Logistics|||Other

Revenue

Under €/$/£10 million|||€/$/£10 million - 50 million|||€/$/£50 million - 150 million|||€/$/£150 million - 1 billion|||Over €/$/£1 billion

Size

0-250|||250-500|||500+

Status

Public

Required

Yes (with phased timelines by group)
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Overview

Introduced: October 2021 (CSA initial draft); CSSB CSDS finalized March 2024
Effective from: Voluntary FY 2025 (reports filed in 2026), Mandatory from FY 2026 (reports filed in 2027)
Region(s): Canada (all provinces and territories via CSA harmonization)

About

Canada’s National Instrument 51-107 (NI 51-107) transitions Canadian issuers from voluntary ESG disclosure to mandatory climate-related financial reporting aligned with the finalized Canadian Sustainability Standards Board (CSSB) standards:

  • CSDS 1: General Requirements for Disclosure of Sustainability-Related Financial Information

  • CSDS 2: Climate-Related Disclosures

These standards mirror the globally recognized IFRS Sustainability Standards (IFRS S1 and S2) developed by the International Sustainability Standards Board (ISSB). The regulation aims to ensure consistent, comparable climate disclosure across governance, strategy, risk management, and key climate metrics, bringing Canada’s financial disclosures into alignment with international best practices.

Disclosure requirements

Companies are required to provide comprehensive disclosures aligned with the CSSB’s CSDS 1 and 2 frameworks, covering:

  • Governance: Board oversight and management roles in monitoring and responding to climate-related risks and opportunities.

  • Strategy: Assessment of climate-related risks and opportunities, including resilience analysis through scenario planning (minimum of two scenarios: one consistent with a 1.5°C pathway).

  • Risk management: Processes for identifying, assessing, and managing climate-related risks integrated into existing enterprise risk management (ERM) frameworks.

  • Metrics and targets:

    • Mandatory reporting of Scope 1 and Scope 2 greenhouse gas (GHG) emissions

    • Scope 3 emissions disclosure required if material, or included in public targets

    • Progress towards publicly disclosed climate-related targets and key performance indicators (KPIs).

Who needs to comply

The following entities must comply:

  • All Canadian public issuers governed by provincial securities regulators (listed on TSX, TSXV, CSE, NEO) and foreign issuers reporting in Canada.

  • Federally regulated financial institutions already required to comply separately under OSFI Guideline B-15 from FY 2024 onward.

Compliance timeline

  • 2024: CSSB CSDS standards finalized (voluntary adoption begins for FY 2025).

  • 2025: Canadian Securities Administrators (CSA) expected to finalize mandatory NI 51-107 reporting requirements.

  • 2027 (covering FY 2026): First mandatory disclosures due, submitted through SEDAR+ alongside annual continuous disclosure documents (MD&A or AIF).

Third-party assurance

Initially voluntary; CSA consultations expected to phase in mandatory limited assurance beginning post-2028. Assurance providers must follow recognized standards and methodologies approved by Canadian regulatory bodies.

Penalties for non-compliance

Entities may face penalties including:

  • Cease-trade orders

  • Administrative monetary penalties up to C$1 million per violation

  • Civil liability for misrepresentations

  • Potential director/officer liability for materially incomplete or misleading disclosures

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