Canada's Climate Disclosure Rules: What You Need to Know

Canada climate disclosure at a glance

Canada's Office of the Superintendent of Financial Institutions (OSFI) requires federally regulated banks and insurers to publish annual climate-related financial disclosures under Guideline B-15, starting with fiscal years ending on or after 1 October 2024 for the six largest banks and four internationally active insurers, and fiscal year 2025 for the others. Every other Canadian company reports voluntarily under the Canadian Sustainability Disclosure Standards (CSDS 1 and CSDS 2), issued on 18 December 2024, while securities regulators keep their mandatory climate rule on hold.

How Canada got here

Canada built the standard first and left the mandate to regulators. The Canadian Sustainability Standards Board issued CSDS 1 and CSDS 2 on 18 December 2024, voluntary "unless mandated by regulators or governments". On the same day the Canadian Securities Administrators said it would publish a revised climate disclosure rule for listed companies that considers the new standards. On 23 April 2025 it paused that work, citing changes in the global economic and geopolitical landscape, and confirmed that existing securities legislation still requires listed companies to disclose material climate-related risks. The federal government announced on 9 October 2024 that it intended to amend the Canada Business Corporations Act to require climate disclosures from large, federally incorporated private companies; Budget 2025, tabled on 4 November 2025, announced that the government will work with provinces and territories to improve climate disclosure across the economy, aligned with international standards.

What Canada's climate disclosure rules require

Federally regulated banks and insurers publish an annual climate-related financial disclosure under Chapter 2 of Guideline B-15, using the four pillars of governance, strategy, risk management, and metrics and targets.

• Guideline B-15: institutions disclose board and management oversight of climate-related risks, the risks and opportunities that affect cash flows, access to finance or cost of capital, how climate risk feeds into enterprise risk management, targets and progress against them, and cross-industry metrics such as assets exposed to transition and physical risk. Disclosures sit in the annual report, a stand-alone climate report or a Pillar 3 report, and are subject to the same internal governance and controls as financial reporting.

• CSDS 1 (General Requirements): the Canadian version of IFRS S1. It adds a two-year climate-first relief, so a company that starts in 2025 reports on all sustainability topics from 2027, and lets companies publish their first three reports after their financial statements (within nine months in year one and six months in years two and three).

• CSDS 2 (Climate-related Disclosures): the Canadian version of IFRS S2, with three years of relief for Scope 3 emissions and for quantitative scenario analysis. The Canadian Sustainability Standards Board consulted until 20 July 2026 on adopting the global greenhouse gas amendments to IFRS S2, proposed effective 1 January 2028, with final approval expected in the fourth quarter of 2026.

• The GHG Protocol as the measurement standard: Guideline B-15 requires the latest GHG Protocol Corporate Standard and Scope 3 Standard, or comparable standards, and the Partnership for Carbon Accounting Financials standard, or a comparable industry approach, for financed and insurance-associated emissions. The Canadian standards use the GHG Protocol Corporate Standard (2004), as the global baseline does.

Who is in scope

Mandatory climate disclosure in Canada applies to federally regulated banks and insurers; every other company reports voluntarily.

Federally regulated banks and insurers

• Domestic systemically important banks: Bank of Montreal, Bank of Nova Scotia, Canadian Imperial Bank of Commerce, National Bank of Canada, Royal Bank of Canada and Toronto-Dominion Bank, from fiscal year 2024.

• Internationally active insurance groups headquartered in Canada: Sun Life Assurance Company of Canada, Manufacturers Life Insurance Company, Canada Life Assurance Company and Intact Financial Corporation, from fiscal year 2024.

• Small and medium-sized deposit-taking institutions: federally regulated banks, and trust and loan companies, from fiscal year 2025.

• All other federally regulated insurers: life, property and casualty, and Canadian branches of foreign insurers for their Canadian business, from fiscal year 2025.

Listed and private companies

Listed companies disclose material climate-related risks under existing securities legislation and can apply CSDS 1 and CSDS 2 voluntarily. Large private companies can do the same while federal and provincial governments set their approach.

Supply-chain reach: Scope 3 disclosure under Guideline B-15 includes Category 15 financed emissions, broken down by asset class and sector, and, for property and casualty insurers, insurance-associated emissions by line of business. From fiscal year 2028, every in-scope bank and insurer needs emissions data from the companies it lends to, invests in or insures, in Canada and abroad, and the regulator lets institutions pair fiscal year 2028 financial data with counterparties' fiscal year 2027 emissions.

Key dates and milestones

The regulator has left the timing of transition plan disclosure, scenario analysis disclosure and financed emissions from assets under management to be determined.

Why this matters beyond Canada

1. Supply-chain ripple through Canadian lenders and insurers. Canada's largest banks and insurers finance and insure companies across North America, Latin America, Europe and Asia. Their fiscal year 2028 financed and insurance-associated emissions depend on counterparty emissions data, so borrowers and commercial policyholders receive data requests whatever their home rules require.

2. Alignment with the global baseline. CSDS 1 and CSDS 2 keep the text of IFRS S1 and IFRS S2 with timing changes, so a Canadian group can build one inventory that also serves the matching rules in the United Kingdom, Australia, Singapore and Japan.

3. Canadian groups meet mandatory rules abroad. American subsidiaries of Canadian groups that have more than $1 billion in revenue and do business in California report Scope 1 and Scope 2 emissions under California's SB 253, with the first report due 10 November 2026. European operations fall under the Corporate Sustainability Reporting Directive once they cross its thresholds.

How companies should prepare

Canadian lenders and insurers disclose Scope 3 for fiscal year 2028 and can use counterparties' fiscal year 2027 emissions to do it, and listed companies can adopt CSDS 2 at any time.

• Establish your greenhouse gas inventory on the GHG Protocol. Scope 1 and Scope 2 on the GHG Protocol Corporate Standard is the entry point for Guideline B-15 and CSDS 2. Build a corporate carbon footprint at the entity level that consolidates cleanly.

• Map your value-chain exposure to Canadian banks and insurers. If a Canadian bank lends to you or a Canadian insurer covers your commercial risks, your emissions become part of their fiscal year 2028 Scope 3 figure, which can draw on your fiscal year 2027 data. Measure your own Scope 1 and Scope 2 for 2027 before the request arrives.

• Build assurance-ready processes early. The regulator expects the same governance and controls as financial reporting and a future state with external assurance. Documented methodology, source-data traceability and review controls answer the auditor's question: where did this number come from?

• Build on the frameworks you already use. Existing four-pillar climate reporting and CDP responses map to Guideline B-15 and CSDS 2. The new work is Scope 3 by category, financed emissions and climate reporting aligned with the global baseline.
  
  

How Terrascope can help

Terrascope's AI-powered platform helps companies across the Americas move from baseline emissions data to audit-ready disclosures, including Frutura, the fruit producer that brought six business units in the United States and Latin America onto one platform, set a fiscal year 2024 baseline ready for science-based targets and ran more than 176 decarbonisation simulations.

• Scope 1, 2, and 3 emissions measurement. Integrations pull emissions data from your source systems monthly, in any format, so your inventory stays current across every entity and Scope 3 category.

• Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with assurance-provider access built in.

• Supply-chain intelligence. Analytics shows where your Scope 3 hotspots sit, so you can answer lender and insurer data requests and plan reductions from the same numbers.

• Multi-framework alignment. ISSB Reporting drafts your CSDS 2 or Guideline B-15 disclosures from your measured data, reviewed by your team.

Frequently asked questions

Speak to an expert

Are you ready to get ahead of Canada's climate disclosure requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.