Several of our blogs over the past few years have discussed the increased focus on mandatory climate-related disclosures and Environmental, Social, and Governance (ESG). This trend has taken a sharp turn in recent months, including an announcement by the Canadian Security Administrators (CSA).
On April 23, 2025, the CSA announced, “The Canadian Securities Administrators (CSA) is pausing its work on the development of a new mandatory climate-related disclosure rule and amendments to the existing diversity-related disclosure requirements. This is being done to support Canadian markets and issuers as they adapt to the recent developments in the U.S. and globally.”
On February 11, 2025, the United States Securities and Exchange Commission (SEC) acting Chairman paused the Climate Disclosure Rule and later ended its defense of the rule.
The announcement said that in response to the changing geopolitical landscape, the CSA is focusing on initiatives to make Canadian markets more “competitive, efficient, and resilient.”
In a recent blog discussing the announcement, Torys LLP provided a summary of recent actions related to climate disclosure rules.
The Canadian Securities Administrators (CSA) is pausing its work on the development of a new mandatory climate-related disclosure rule and amendments to the existing diversity-related disclosure requirements (Photo by Patrick Hendry on Unsplash).
Changing Climate Disclosure Landscape
CSA pauses climate disclosure rule. The CSA has paused its efforts to finalize a mandatory climate change disclosure rule for Canadian issuers, citing recent developments in the U.S. and globally. The CSA will monitor developments and may revisit the project in the future.
Proposed CBCA amendments. Previously-proposed amendments to the Canada Business Corporations Act (CBCA) by the Government of Canada contemplated mandatory climate-related financial disclosures for large, federally-incorporated private corporations. However, the CSA’s decision to pause its climate disclosure rule, coupled with the recent Canadian election and global political and economic uncertainty, suggests that these amendments may not be implemented in the near future.
Updated Guideline B-15 for FRFIs. The Office of the Superintendent of Financial Institutions (OSFI) issued the final version of Guideline B-15 for federally-regulated financial institutions (FRFIs). Key changes include extending the implementation date for disclosure of Scope 3 greenhouse gas (GHG) emissions to fiscal-year-end 2028 to align with the phase-in period for the Canadian Sustainability Standards Board (CSSB) sustainability disclosure standards.
Legal uncertainty surrounding SEC climate disclosure rules. The SEC’s climate disclosure rules have faced significant legal challenges and regulatory uncertainty, which have been appealed to the U.S. Court of Appeals for the Eighth Circuit. On March 27, 2025, the SEC announced that it had voted to end its defense of its rules.
Canadian Banks Backtracking
On March 27, 2025, we reported that several Canadian Banks were leaving the Net Zero Banking Alliance, including the Canadian Imperial Bank of Commerce, Toronto-Dominion Bank, Bank of Montreal, and National Bank of Canada. This list also includes the Royal Bank of Canada (RBC). Additionally, RBC announced it is abandoning its sustainable finance commitments. According to the Financial Post (paywall), “RBC, Canada’s biggest bank, cited changes to the country’s Competition Act that restrict the kinds of environmental claims firms can make.”
We have discussed the Competition Act on several occasions (most recently in a January 31, 2025, blog).
The sudden course change in the various green policies and practices is a reminder of the global interconnectedness of not only environmental polices but economies as well.
Environmental Compliance
The changes aside, the regulated community has no shortage of environmental obligations. On the Provincial level, permits to discharge, management of excess soil, brownfield programs (e.g., Ontario Record of Site Condition), and water-taking requirements are a few examples.
Federally, we need to monitor the developments related to per- and polyfluoroalkyl substances (PFAS). Addressing PFAS is potentially very consequential.
Environmental Assistance
If you have questions or need assistance with an environmental issue, contact our office or contact Christopher Paré, P.Geo., directly at 519-948-7300, Ext. 114.
Alan Hahn drafted this blog. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for more than 45 years. He has written hundreds of blogs and articles. His published work includes HazMat Magazine, BizX Magazine, Michigan Lawyers Weekly, GreenStone Partners, Manure Manager Magazine, and Progressive Dairy.
Christopher Paré, P.Geo, reviewed this blog. Chris is a senior geoscientist and manager of Dragun’s Windsor, Ontario, office. Chris has more than 30 years of experience on projects ranging from environmental site assessments (Phase One/Two ESA), excess soils, remedial investigations, soil and groundwater remediation, Permits to Take Water, Records of Site Conditions, vapour intrusion, and site decommissioning. Chris is a frequent speaker, author, and expert witness. See Chris’ bio. Follow Dragun Corporation on LinkedIn, X, or Facebook.
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