CSDS 1 and CSDS 2 – Canadian Sustainability Disclosure Standards

OSFI guideline setting expectations for climate risk governance, strategy, risk management, scenario analysis, and capital and liquidity adequacy at federally regulated financial institutions. Chapter 2 sets public climate disclosure expectations; the March 2025 version aligned Scope 3 timing with the CSSB's CSDS 2 (fiscal 2028).

Enforcement

Mandatory for federally regulated financial institutions

Effective date

Chapter 2 disclosures apply to fiscal periods ending on or after 1 October 2024 (D-SIBs and IAIGs headquartered in Canada) and 2025 (other in-scope FRFIs), with cross-industry metrics one year later; Scope 3 financed and insurance-associated emissions and industry-based metrics from fiscal year-end 2028; AUM emissions, transition plan and scenario resilience disclosures TBD

Covered entities

All FRFIs except foreign bank branches; applies to Canadian branches of foreign insurers only for risks insured in Canada. Chapter 2 disclosures exclude FRFI subsidiaries that report consolidated results to OSFI.

Two deceptive marketing provisions target environmental claims. Product claims about benefits for protecting or restoring the environment or mitigating the causes or effects of climate change must be based on an adequate and proper test (paragraph 74.01(1)(b.1)). Claims about the environmental benefits of a business or business activity must be based on adequate and proper substantiation (paragraph 74.01(1)(b.2)); since 26 March 2026 that substantiation no longer has to follow an internationally recognized methodology, and private parties cannot seek leave to bring (b.2) cases. For corporations, administrative monetary penalties can reach the greater of CAD 10 million (CAD 15 million for later orders) and three times the benefit derived or, if that cannot be determined, 3 percent of annual worldwide gross revenues.

Enforcement

Mandatory

Effective date

20 June 2024

Covered entities

Any person making representations to the public in Canada about a product, business or business activity that relate to environmental or social benefits or effects

In-scope entities and government institutions must file an annual report to the Minister of Public Safety by 31 May describing the steps taken in the prior financial year to prevent and reduce forced labour and child labour risks in their activities and supply chains, and publish the report on their website. The Act amends the Customs Tariff to prohibit imports of goods made with forced or child labour. Offences carry fines up to CAD 250,000 and director/officer liability.

Enforcement

Mandatory

Effective date

1 January 2024; first annual reports due by 31 May 2024 and each 31 May thereafter

Covered entities

Government institutions producing, purchasing, or distributing goods, plus 'entities' (corporations, trusts, partnerships, or other unincorporated organisations) that are listed on a Canadian stock exchange, or have a place of business in Canada, do business in Canada, or have assets in Canada and meet at least two of: CAD 20 million in assets, CAD 40 million in revenue, or 250 employees on average (worldwide, in at least one of the two most recent financial years), and are involved in producing, importing, or distributing goods.

EPR in Canada is set province by province under the CCME action plan, with British Columbia, Ontario and Quebec running the most developed full producer-funded systems for packaging, paper, electronics, batteries and other product streams. Ottawa has no overarching federal EPR statute; CEPA underpins toxic-substances rules and federal coordination, while provinces operate the schemes through PROs such as Recycle BC, Circular Materials and Éco Entreprises Québec.

Enforcement

Mandatory

Effective date

BC packaging EPR since 19 May 2014; Ontario Blue Box transition to full producer responsibility ran 1 July 2023 to 31 December 2025; Quebec modernized packaging EPR effective 1 January 2025; Alberta packaging, paper and hazardous and special products EPR launched 1 April 2025 (remaining communities 1 October 2026); EEE, batteries, tires and paint schemes since the 2000s

Covered entities

Producers (brand owners, first importers, distributors) of packaging, printed paper, EEE, batteries, tyres, paint, lamps, used oil and other regulated products in each province; thresholds vary (e.g., Ontario small-producer exemption below CAD 2 million revenue or 1 tonne supplied)

Australia has adopted ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory for entities within Chapter 2M of the Corporations Act and is phased in across three groups from 2025 to 2027. AASB S1 (general sustainability) is voluntary. ASIC administers the regime and has published guidance in RG 280.

Enforcement

AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.

Effective date

Financial years beginning on or after 1 January 2025 (Group 1), 1 July 2026 (Group 2) and 1 July 2027 (Group 3). AASB S2025-1 amendments apply to annual periods beginning on or after 1 January 2027, with early application permitted.

Covered entities

Entities that must prepare annual financial reports under Chapter 2M of the Corporations Act and meet a s292A threshold. Group 1: at least two of consolidated revenue of AUD 500m or more, consolidated gross assets of AUD 1bn or more, and 500 or more employees; or NGER registered corporations in groups that meet the s13(1)(a) NGER threshold. Group 2: at least two of revenue of AUD 200m or more, assets of AUD 500m or more, and 250 or more employees; all other NGER registered corporations; and registered schemes, RSEs and retail CCIVs with assets of AUD 5bn or more. Group 3: at least two of revenue of AUD 50m or more, assets of AUD 25m or more, and 100 or more employees.

UK SRS S1 and S2 are the UK government's endorsed versions of IFRS S1 and S2, published on 25 February 2026 for voluntary use. Voluntary users can apply the Scope 3 and non-climate reliefs with no time limit. The FCA has consulted on listing rules that would make UK SRS S2 climate reporting mandatory for listed companies, with Scope 3 emissions and UK SRS S1 non-climate reporting on a comply-or-explain basis.

Enforcement

Voluntary at publication. FCA proposes mandatory UK SRS S2 for listed issuers (Scope 3 and broader sustainability on comply-or-explain).

Effective date

Voluntary use: no effective date (entities apply the standards when they choose). FCA proposal, subject to the final policy statement: rules in force 1 January 2027 for accounting periods beginning on or after 1 January 2027; using the transitional reliefs, Scope 3 reporting from periods beginning on or after 1 January 2028 and UK SRS S1 non-climate reporting from periods beginning on or after 1 January 2029.

Covered entities

Any entity (voluntary). The FCA proposal covers issuers in the commercial companies (UKLR 6), non-equity and non-voting equity shares (UKLR 16), transition (UKLR 22), secondary listing (UKLR 14) and depositary receipts (UKLR 15) categories. No mandate yet for unlisted companies.