Governance Insights (September 2022)

CHAPTER 05 Competing Frameworks: Mandatory Climate Disclosure Is (Almost) Here

Spotlight: Key Elements of Leading Climate Disclosure Proposals and Frameworks

This table summarizes the key elements of the CSA Proposal, noting where such elements part ways with the TCFD framework, the SEC Proposal, and the ISSB Proposal. Key differences

CSA Proposal

Governance disclosure to be made in issuer’s management information circular, annual information form or management’s discussion and analysis, with other disclosure (strategy, risk management, metrics and targets). Two options are being considered: Option 1: Scope 1 Emissions, Scope 2 Emissions and Scope 3 Emissions, or issuer’s reasons for not making such disclosure. Option 2: Scope 1 Emissions and either disclose Scope 2 Emissions and Scope 3 Emissions or explain why no such disclosure was made.

Publication

include the CSA’s less stringent requirements for reporting upstream and downstream GHG

GHG Emissions Scope 1 Emissions: produced directly by issuer’s operations Scope 2 Emissions: indirectly resulting from issuer’s energy use Scope 3 Emissions: other indirect emissions upstream (e.g., extraction and production of inputs, outsourcing) or downstream (e.g., transport and use of products, waste disposal) Scenario Analysis Resiliency of strategy, considering different climate scenarios (including global average temperature increase of 2°C above pre- industrial level, or less)

emissions, and the absence of a requirement to consider risks related to different temperature scenarios.

Not required.

Climate/Transition Plans and GHG Emission-Reduction Targets (Regulated or Voluntary)

Disclosure of issuer’s climate targets required if material.

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