CSSB Exposure Draft Survey: “Proposed amendments to CSDS 2: Amendments to Greenhouse Gas (GHG) Emissions Disclosures”

Have your say on CSDS 2: GHG Emissions Disclosures

The CSSB is seeking feedback on its Exposure Draft, “Proposed amendments to CSDS 2: Amendments to Greenhouse Gas (GHG) Emissions Disclosures.” Your input will help guide the finalization of CSDS 2, Climate-related Disclosures.

Background

In January 2025, the International Sustainability Standards Board (ISSB) proposed amendments to IFRS S2 and released its Exposure Draft, “Amendments to Greenhouse Gas Emissions Disclosures – Proposed amendments to IFRS S2,” and related Basis for Conclusions in April 2025. Their Exposure Draft suggested providing additional relief and clarifying existing relief from specific greenhouse gas (GHG) emissions disclosure requirements.

CSSB Concerns

The CSSB, along with other Canadian respondents, raised concerns about granting permanent relief that could allow entities to exclude Scope 3 Category 15 GHG emissions associated with facilitated and insurance-associated activities from their disclosures. Non-Canadian respondents expressed similar concerns. These concerns reflect the importance of ensuring complete disclosure of material GHG emissions, including material Scope 3 emissions, and the evolving measurement methodologies for emissions associated with financial activities.

Current CSSB Proposal

The CSSB Exposure Draft is proposing a Canadian modification to the effective date and seeks input on the best path forward to serve the Canadian public interest. On the issue of permanent relief to exclude Scope 3 Category 15 GHG emissions associated with facilitated and insurance-associated activities from entity disclosures, the CSSB is not proposing a Canadian modification, and your input is requested on this matter as well.

Based on your feedback, the CSSB will consider modifications to CSDS 2 before finalizing it in the final quarter of 2026.

Your input is crucial to meet the needs of sustainability standard-setting in Canada. We look forward to your insights!

Who should participate?

We welcome input from all interested and affected parties, including:

• Banking institutions
• Insurance organizations
• Asset Management
• Regulators
• Indigenous Rightsholders, Leaders, and organizations
• Climate advocacy organizations
• Preparers (other than financial sector)

Privacy and Confidentiality

By completing this survey, you consent to the collection and use of information as described below.

FRAS Canada values your participation in the research it conducts and will safeguard the information you provide. The information will only be made available to those within FRAS Canada, including Board members, who require use of it for verification, analysis and/or deliberation purposes. We use a third-party software to store and analyze responses, including related personal information such as name of the submitter. This information may be stored outside of Canada. Appropriate data retention and destruction practices will take place following completion of the project. Should you wish to withdraw your consent or if you have any questions about the processing of your personal information, please contact us at info@frascanada.ca.