Feedback Statement – Criteria for Modification, CSDS 1 and CSDS 2

On March 13, 2024, the Canadian Sustainability Standards Board (CSSB) released three key documents for public comment that were open for 90 days:

• Consultation Paper, “Proposed Criteria for Modification Framework”, which presented the basis on which the CSSB could introduce changes to the IFRS® Sustainability Disclosure Standards as issued by the International Sustainability Standards Board;
• Exposure Draft, “Proposed CSDS 1, General Requirements for Disclosure of Sustainability-related Financial Information”; and
• Exposure Draft, “Proposed CSDS 2, Climate-related Disclosures.”

We conducted extensive outreach on the three documents for comment and provided interested and affected parties with opportunities to provide feedback on the proposals through consultation sessions, response letters, and online surveys. Through these activities, we engaged with approximately 3,900 individuals. Of those individuals, 529 provided feedback on the consultation questions.

We appreciate the exceptional engagement and the volume of feedback from interested and affected parties.

Who responded

We received feedback from a diverse cross-section of individuals and organizations, representing a wide range of interests, perspectives, and expertise. This diversity of perspectives is crucial to informing our standard-setting work.

Much of the feedback came from those directly involved in or affected by the standards, such as those who prepare or use sustainability disclosures and the professional services that support them. Additionally, respondents included representatives from governments, regulators, policymakers, and participants from academia, advocacy groups, standard setters, and framework developers.

We also received feedback from Indigenous Peoples, communities, organizations and leaders, ten of Canada’s 13 provinces and territories, and from French speakers. A separate report based on Indigenous participation and feedback related to Indigenous matters is forthcoming.

Despite this fulsome response to our request for input, we recognize that there were interested and affected parties who were not reached through our consultation channels.

We are committed to improving the representation of interested and affected parties in our future work and are actively working to do this as part of a 2025 consultation on our multi-year strategic plan.

What we heard

This wide variety of interested and affected parties shared an equally wide array of views, comments, thoughts, and suggestions on the three documents for comment.

Respondents commented on such topics as the following:

• The CSSB’s questions on each of the three documents open for public comment.
• Alignment with the International Sustainability Standards Board’s baseline standards (IFRS S1 and IFRS S2).
• Regulatory considerations.
• Costs and capacity to disclose information.
• Data availability and quality.
• Accounting methodologies for greenhouse gas emissions calculations.
• Education, guidance, and support for implementation of these standards.
• The urgency for standardized sustainability disclosure.

Read the feedback from respondents who granted us permission to publicly release their letters and survey responses.

What’s next

We are currently finalizing our deliberations on the feedback received during the consultation process. CSDS 1 and CSDS 2 are expected to be officially issued in December 2024.

Keep up to date with our activities via our post-meeting decision summaries.