The Canadian Securities Administrators (CSA) announced on April 23, 2025, that it will pause the development of a new mandatory climate-related disclosure rule and amendments to the existing diversity-related disclosure requirements. The CSA stated that it is doing so in order to support Canadian markets and issuers as they adapt to the recent developments in the US and globally. The CSA pointed to the current market conditions and changes in geopolitics which have resulted in increased worries regarding competitiveness, rising uncertainty and global economic factors.

Although the CSA has delayed its initial timeline, the underlying rationale for climate-related disclosures remains. Securities legislation already compels issuers to disclose material climate risks just as they would any other material factor that affects their business. The recent introduction of sustainability standards by the Canadian Sustainability Standards Board, largely aligned with international disclosure frameworks, gives Canadian issuers a voluntary benchmark for consistency and comparability. This means that while new rules are on hold, issuers should continue to identify and assess climate-related exposures so that they can disclose them accurately and transparently.

On the diversity front, the CSA’s decision means that non-venture issuers will continue adhering to existing rules that require disclosure of female representation on boards and in senior executive roles, based on the existing requirements under National Instrument 58-101 Disclosure of Corporate Governance Practices. The announced pause indicates that the CSA wants to ensure that any further enhancements to disclosure rules are attuned to a rapidly shifting regulatory and economic environment.

In practical terms, issuers should view this pause not as a dismantling of the CSA’s sustainability and diversity initiatives, but rather as a strategic alignment effort. The CSA clearly intends to revisit these projects in due course, providing stakeholders with further clarity regarding climate-related and diversity-related disclosures. In the meantime, engaging in best practices and building robust internal controls for data collection, transparency and risk management will position organizations favourably when the regulatory landscape evolves once again.

With geopolitical forces and global competition weighing on markets, it is prudent for business leaders to continue monitoring both domestic and international developments in sustainability and diversity disclosures. Keeping abreast of voluntary standards, such as those introduced by the Canadian Sustainability Standards Board, and integrating them into annual reporting and strategic planning will help to keep stakeholders informed, mitigate greenwashing risks and ensure ongoing compliance with general disclosure requirements. Ultimately, proactive engagement with the evolving ESG framework will enable companies to respond effectively regardless of when and how the CSA reintroduces its new requirements.

For further information or assistance, please contact author Diana Nakka or any other member of our Securities and Corporate Finance group.