The Pension Investment Association of Canada supports closely aligning the Canadian Sustainability Standards Board disclosure standards with the International Sustainability Standards Board’s requirements but recommends it only make necessary Canadian-specific modifications to the guidance.
In an open letter to the CSSB, the PIAC noted alignment between financial and sustainability reporting supports “a connectivity that is essential in the evaluation of entities’ value and understanding of the impacts of sustainability risks and opportunities.” However, it said modification for a Canadian context should only be made to strengthen this connectivity.
The association also recommended alignment with the ISSB’s application of transition relief for only the first reporting period, rather than the two-year transition relief for disclosures beyond climate-related risks and opportunities proposed in the exposure draft.
Read: PIAC providing feedback on ISSB’s sustainability, climate change exposure drafts
“Alignment with ISSB’s application of transition relief streamlines the process for the reporting entities which must adhere to both guidelines,” said the PIAC. “Moreover, Canadian regulators mandate standard(s) adoption and adherence and can work with regulated entities, including pension plans, to determine if disclosure deferrals are necessary and/or appropriate.”
As well, the association said it believes no additional transition relief for climate-resilience disclosure is required, noting climate-related scenario risk analysis is a well-developed and important existing strategic exercise for many Canadian issuers. Proposed proportionality mechanisms in Canadian Sustainability Disclosure Standards for S2 emissions for first-time users/reporters are sufficient, it added.
In terms of Scope 3 emissions measurements, it said the standard already provides for proportionality in relation to disclosures of Scope 3 emissions and that regulators are equipped to monitor the need for additional deferrals.
Read: PIAC focusing on pension solvency uniformity, CAPSA risk management guidelines in 2024