The Pension Investment Association of Canada (PIAC) urges the alignment of the Canadian Sustainability Standards Board (CSSB) disclosure standards with those of the International Sustainability Standards Board (ISSB), recommending only necessary Canadian-specific modifications.
In an open letter to the CSSB, the PIAC emphasized that aligning financial and sustainability reporting is essential for evaluating entities’ value and understanding sustainability risks and opportunities. Any Canadian-specific adjustments should enhance this connectivity.
The PIAC also suggested that the CSSB align with the ISSB’s application of transition relief for just the first reporting period, rather than the proposed two-year transition relief for non-climate-related disclosures in the exposure draft. The PIAC stated, “Alignment with ISSB’s application of transition relief streamlines the process for reporting entities that must adhere to both guidelines.” They also emphasized that Canadian regulators should mandate the adoption and adherence to standards, working with entities, including pension plans, to determine the necessity and appropriateness of disclosure deferrals.
Furthermore, the PIAC argued against additional transition relief for climate-resilience disclosures, noting that climate-related scenario risk analysis is a well-established and crucial strategic exercise for many Canadian issuers. They indicated that the proposed proportionality mechanisms in the Canadian Sustainability Disclosure Standards for S2 emissions are sufficient for first-time reporters. Regarding Scope 3 emissions measurements, the PIAC pointed out that the standard already allows for proportionality in disclosures and that regulators can assess the need for further deferrals.
