Pensions and Benefits Law Blog

Proposed climate change risk disclosure is good for both pension plan administrators and members

Nov 25, 2021 1 MIN READ
Jonathan Wypych

Associate, Pensions and Benefits, Toronto

Andrea Boctor

Partner, Pensions and Benefits, Toronto

Pen resting on an open book full of charts and graphs. A calculator is also visible just in the corner of the frame.

On October 18, 2021, the Canadian Securities Administrators (CSA) published for comment Proposed National Instrument 51-107 Disclosure of Climate-related Matters and its accompanying Companion Policy 51-107CP Disclosure of Climate-related Matters. The proposed National Instrument would establish climate-related disclosure obligations for reporting issuers in Canada. Osler has recently published an in-depth review of this proposed National Instrument, in the blog post, Climate change from the corporate perspective: the CSA’s proposed climate-related disclosure requirements.

Given the increased focus on managing the financial risks posed by climate change, pension plan administrators will benefit from the enhanced and standardized disclosure proposed in the draft National Instrument. With complete, consistent and comparable disclosure from issuers, pension plan administrators will be able to more prudently assess and manage the financial risks associated with climate change. In addition to making more prudent investment-decisions, pension plan administrators will also be in a position to provide information to plan members on how climate-related risks are being managed.  Though not a statutory requirement in Canada, member disclosure on climate-related financial risks is a feature in the United Kingdom and other jurisdictions, and members of Canadian plans are increasingly requesting this information. 

The CSA is providing the public with a 90-day comment period on the proposed National Instrument and Companion Policy. The comment period closes January 17, 2022.