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. Includes financial disclosure expectations being aligned with CSSB's CSDS standards.

Enforcement

Mandatory for federally regulated financial institutions

Effective date

Fiscal year-end 2024 for D-SIBs and IAIGs headquartered in Canada. Fiscal year-end 2025 for all other in-scope FRFIs.

Covered entities

All federally regulated financial institutions (FRFIs)

The amendments add two new deceptive marketing provisions targeting environmental claims: product-level claims about benefits for protecting or restoring the environment must be backed by adequate and proper testing, and business-level claims about environmental performance must be based on adequate and proper substantiation in line with internationally recognised methodology. Penalties reach the greater of CAD 10 million for a first offence or 3 percent of 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.

Australia has issued ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory under the Corporations Act for in-scope entities; AASB S1 (broader sustainability) is voluntary.

Enforcement

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

Effective date

Annual reporting periods beginning on or after 1 January 2025 (phased by entity size)

Covered entities

Group 1, 2, 3 entities under AASB thresholds (large entities first; phased rollout to mid-size and smaller large entities)

The UK government has endorsed IFRS S1 and S2 as UK SRS S1 and S2 for voluntary use. The FCA is consulting on listing rules that would make UK SRS S2 mandatory for listed issuers, with Scope 3 and non-climate sustainability 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

TBD pending FCA listing-rule outcome

Covered entities

Any UK entity (voluntary). FCA proposal targets in-scope listed issuers.

SSBJ published final sustainability disclosure standards on 5 March 2025: an Application Standard, a General Standard, and a Climate Standard. The standards are essentially equivalent to IFRS S1 and S2. Mandatory application phases in by market capitalization.

Enforcement

Voluntary now. Mandatory under FSA disclosure framework on phased basis by market cap.

Effective date

Voluntary for periods ending on or after 5 March 2025. Mandatory phased: FY ending March 2027 for issuers with market cap >¥3T, expanding through FY ending March 2029.

Covered entities

Listed issuers in Prime Market (phased by market cap)