ESG Reporting Requirements in Canada: CSA Rules, OSFI B-15 & ISSB

Canada's ESG and sustainability reporting landscape is evolving rapidly, driven by securities regulators, financial sector supervisors, and growing investor pressure. Unlike the EU's single CSRD mandate, Canadian requirements are fragmented across securities regulation, financial sector supervision, and stock exchange rules — with ISSB-aligned disclosure standards forming the emerging common framework.

For companies with Canadian operations, a listing on the Toronto Stock Exchange, or significant revenue from Canadian institutional investors, understanding which requirements apply — and when — is an important aspect of investor relations, risk management, and corporate stewardship.

Federal and Provincial Securities and Related ESG Regulations

Canada's securities regulation operates at the provincial level, coordinated through the Canadian Securities Administrators (CSA) — an umbrella body of provincial and territorial securities regulators. The CSA has been developing mandatory climate-related disclosure rules aligned with ISSB S1 and S2.

In October 2024, the CSA published final rules requiring climate-related disclosures for most reporting issuers (publicly listed companies) on the TSX and TSX Venture Exchange. The rules follow the ISSB S1 and S2 structure, covering governance, strategy, risk management, and metrics and targets including Scope 1, 2, and material Scope 3 emissions. Key implementation details:

• Non-venture issuers (TSX-listed): phased in from fiscal years commencing on or after 1 January 2025 for the largest companies, extending to smaller issuers by 2027
• Venture issuers (TSX-V listed): extended transition period; lighter-touch requirements in the first phase
• Scope 3 disclosures: subject to a safe harbour provision for good-faith estimates; not required in the first year for most issuers
• S-211 supply chain due diligence reporting: An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff (Bill S-211), is a law passed by Canada's Parliament which took effect January 1, 2024. The bill focuses on forced labour, child labour, and human rights in supply chains, and requires companies to explain how they’re preventing and reducing the risk of forced and child labour in their own supply chain. This aligns with recent EU laws which are also making supply chain due diligence a target topic for ESG legislation. Disclosures must be submitted annually to the Minister of Public Safety and Emergency Preparedness (Public Safety Canada)
• All Canadian corporations must report at least annually on the corporation's board and management diversity
• Note: British Columbia and Ontario initially opted out of certain CSA coordination arrangements but remain subject to their own parallel provincial rules that are substantively similar

OSFI — Financial Sector Climate Disclosure

The Office of the Superintendent of Financial Institutions (OSFI) has separate, more stringent requirements for federally regulated financial institutions — banks, insurance companies, and trust and loan companies. OSFI Guideline B-15 (Climate Risk Management), effective for fiscal years beginning on or after 1 November 2024, requires:

• TCFD-aligned climate risk disclosures (governance, strategy, risk management, metrics and targets)
• Scope 1 and Scope 2 GHG emissions, plus Scope 3 Category 15 (investments — financed emissions) for applicable institutions
• Scenario analysis under at least two climate scenarios, including a scenario consistent with limiting warming to 1.5°C or 2°C
• Transition planning disclosure — how the institution intends to manage climate-related transition risk in its portfolio and operations

B-15 applies to all Domestic Systemically Important Banks (D-SIBs) — currently the 'Big Six': RBC, TD, Scotiabank, BMO, CIBC, and National Bank — plus large insurance groups. Smaller federally regulated financial institutions have extended transition timelines but are expected to align progressively.

For companies that are customers or counterparties of Canadian financial institutions, financed emissions disclosure under B-15 means their scope 1 and 2 data will increasingly be requested by lenders and investors as part of portfolio carbon accounting.

TSX and Investor Expectations

Beyond regulatory requirements, the Toronto Stock Exchange has incorporated ESG disclosure expectations into its issuer guidelines. The TSX's ESG Guidance document encourages (though does not mandate) disclosure aligned with internationally recognised frameworks including GRI, SASB, and TCFD/ISSB.

Institutional investor expectations in Canada operate through two primary channels: direct engagement by large asset managers (CPP Investments, Ontario Teachers', Caisse de dépôt — all of which have published net zero commitments and portfolio decarbonisation targets) and proxy voting policies that increasingly tie board accountability to climate and ESG risk management quality.

CPP Investments — one of the world's largest pension funds — has published detailed expectations for portfolio companies on climate strategy, Paris-aligned targets, and disclosure quality. Companies that cannot provide ISSB-aligned climate data face escalating engagement and, in cases of persistent underperformance, voting against board directors.

Voluntary Frameworks in Use

Many Canadian companies reporting voluntarily or ahead of mandatory requirements use:

• ISSB S1 and S2: the emerging global baseline, directly mapped to CSA's mandatory rules and OSFI B-15. Adopting ISSB now positions companies for compliance without redoing disclosure frameworks later.
• GRI Standards: widely used for comprehensive stakeholder-facing sustainability reports covering environmental, social, and governance topics beyond climate. GRI and ISSB are designed to be used together — GRI for impact materiality, ISSB for financial materiality.
• CDP: the Climate, Water, and Forests questionnaires are widely used by Canadian companies responding to institutional investor requests. CDP scores feed into investor ESG ratings and supply chain disclosure requests from multinationals.
• SASB: sector-specific metrics used alongside ISSB or as standalone guidance for financially material ESG data.

Practical Implications for Canadian Companies

For TSX-listed companies, the path to compliance with CSA's mandatory rules follows four practical steps:

• Determine your group and commencement date — confirm whether the CSA rules adopted in your province apply and from which fiscal year; check provincial opt-out status if relevant
• Baseline Scope 1 and 2 emissions — the data quality standard for mandatory disclosure is higher than for voluntary reporting; establish auditable source documentation and calculation methodology now
• Identify material Scope 3 categories — for many Canadian companies, Category 11 (use of sold products) and Category 15 (investments) are the largest Scope 3 categories; the safe harbour provision provides some relief in year one but is not a long-term deferral
• Assess scenario analysis capability — at minimum, a qualitative 1.5°C scenario analysis is expected; quantitative financial impact assessment under multiple scenarios is the direction of travel

For federally regulated financial institutions, OSFI B-15 requires immediate action on financed emissions data — which requires engaging corporate borrowers and investees on their Scope 1 and 2 data. This creates both a compliance obligation and a commercial opportunity: companies with clean, auditable GHG data are easier for banks to lend to.

See our existing guide on Canada ESG reporting for broader context on the Canadian ESG landscape, and ESG reporting software for platforms that support ISSB-aligned disclosures, S-211 compliance, and other reporting needs.

Canada's position — national standards published but not mandated — is unusual among major markets. For how it compares with the mandatory regimes now in force elsewhere, see our overview of ESG regulations and reporting laws by country.