Issuers are thus encouraged to review and update their internal reporting procedures, where necessary, to ensure that corporate developments are appropriately elevated to the individuals within the organization who are responsible for assessing the issuer’s disclosure obligations in real time, including materiality determinations. For more on this topic, refer to our bulletin Supreme Court of Canada Affirms Broad Definition of “Material Change”. 4. G reenwashing and the Continued Relevance of Climate-Related Disclosure “Greenwashing” rules under the Competition Act , which capture claims made outside the securities law context, continue in effect in Canada for 2026, with further changes expected in the near term. Although these rules continue to evolve, one message is clear: issuers making environmental claims should ensure that they have sufficient substantiation for those claims. In 2025, the Canadian Securities Administrators (CSA) announced that it was pausing its work on mandatory climate-related disclosure rules in an effort to “support Canadian markets and issuers as they adapt to the recent developments in the U.S. and globally.” Commenting on the CSA announcement, the chief executive officer of the Ontario Securities Commission stated that the pause would not be “indefinite,” but also suggested that it could be years before the CSA would revisit its climate disclosure rule, which has remained in draft since 2021. Notwithstanding the pause, the CSA has reminded issuers that existing securities legislation requires disclosure of material climate-related risks and related matters, and that the CSA remains on the lookout for overly promotional greenwashing claims by issuers. For more on this topic, see Greenwashing and Climate- Related Disclosure (Page 12).
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Governance Insights 2026
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