Summary
Details
- Canada
NI 51-107 is not mandatory because it is not in force.
Criteria:
Separately, issuers remain subject to existing Canadian securities law requirements to disclose material risks and material information, which can include climate-related risks where material.
Exceptions:
Since NI 51-107 is paused and not in force, its proposed scope carve-outs and phase-ins do not currently apply as binding requirements.
In practice, any “exception-like” outcomes today come from general securities law materiality assessments, issuer-specific circumstances, and the nature of voluntary disclosure choices.
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What’s Required
If implemented as proposed, NI 51-107 would have required reporting issuers to provide standardized climate-related disclosure within continuous disclosure filings, including:
Governance oversight of climate-related risks and opportunities.
Strategy, risk management, and how climate issues affect the business.
Metrics and targets are used to assess and manage climate-related issues.
Potentially scenario analysis and, in some versions of the proposal, a phased approach and proportionality options.
Important Deadlines
Paused: No binding deadlines for implementation because the rule is not in force.
Ongoing: Existing continuous disclosure requirements under securities law apply with standard periodic filing deadlines (e.g., quarterly and annual financial statements), which may include climate risk disclosures if material.
Current Status
The CSA published the proposed NI 51-107 package in 2021.
On April 23, 2025, the CSA announced it is pausing work on a new mandatory climate-related disclosure rule and related diversity amendments.
Penalties for Non-Compliance
Because NI 51-107 is not in force, there are no NI 51-107-specific penalties.
However, climate statements made voluntarily (or within existing continuous disclosure documents) can still create exposure under general securities law for misleading disclosure or failure to disclose material information, depending on the facts and applicable provincial securities regimes.
Examples for Known Violations
A TSX-listed issuer that publishes a net-zero plan in an annual report is not following NI 51-107, but it still needs to ensure statements are not misleading and that material climate risks are appropriately disclosed under existing rules.
An issuer considering whether to disclose Scope 3 emissions would treat NI 51-107 as a reference framework, but would base any required disclosure on materiality and current securities guidance, not on a binding instrument.
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