The CCAQ supports the establishment of a global baseline for sustainability reporting, and we understand that there is widespread stakeholder support for the creation and adoption of a standardized sustainability risk assessment and a climate-related metric disclosure standard.

However, we believe that there are challenges with the application and implementation of these standards. Those implementing these standards could benefit from:

  1. An extended transition period for adoption of the standard
  2. Consideration of a phased transition period or a “safe harbour” provision for good faith estimates
  3. Additional considerations for small to medium sized public enterprises
  4. Practical guidance on how to apply “undue cost and effort” for small to medium sized public enterprises
  5. Standardization for scenario analysis and quantification techniques for climate resilience
  6. The development of verifiable sources of information for GHG emission metric disclosure in the Canadian market

French language comment letter is coming soon.