Canada's Climate Disclosure Landscape: CSDS, OSFI B-15, and What to Prepare Now

Canadian climate disclosure moved fast and then paused, which has left a lot of teams unsure what actually applies to them. The reality in 2026 is a three-part landscape: national standards that are technically voluntary (CSDS 1 and CSDS 2), a prudential regime that is mandatory for federally regulated financial institutions (OSFI Guideline B-15), and a securities-commission rule that has been put on hold.

None of that changes the underlying direction. Both Canadian standards align with the global ISSB baseline, and all of them point to the same GHG Protocol accounting underneath. The organizations that treat the current pause as a reason to stop are the ones that will be scrambling when the requirements harden. The organizations that use it to build a clean measurement base will be ready.

This guide lays out each piece, the effective dates that matter, and a practical list of what to prepare now regardless of where the mandatory line eventually lands.

The three pieces of Canadian climate disclosure

CSDS 1 and CSDS 2 explained

On December 18, 2024, the Canadian Sustainability Standards Board released Canada's first two standards: CSDS 1, general requirements for sustainability-related financial disclosure, and CSDS 2, climate-related disclosures. Both are effective for annual reporting periods beginning on or after January 1, 2025, and both are built to align with the ISSB's IFRS S1 and S2.

• CSDS 2 requires disclosure of climate-related risks and opportunities across four pillars: governance, strategy, risk management, and metrics and targets, including gross Scope 1, 2, and 3 greenhouse gas emissions.
• The standards are voluntary today. They become mandatory only if adopted by the Canadian Securities Administrators or required by other legislation.
• Transition relief exists: for the first two years, an entity applying CSDS 1 can limit its disclosure to the climate information required by CSDS 2, rather than the broader sustainability scope.
• Emissions must be measured under the GHG Protocol Corporate Standard, the same accounting basis as ISSB S2.

OSFI B-15 for federally regulated financial institutions

The one piece that is unambiguously mandatory is OSFI Guideline B-15, Climate Risk Management. It applies to federally regulated financial institutions (banks, insurers, and similar entities) and sets expectations across two chapters: governance and financial disclosures. OSFI updated the guideline in March 2025 to keep it interoperable with the CSSB standards.

B-15 matters beyond the institutions it binds directly. Banks and insurers subject to it will increasingly ask their borrowers, tenants, and corporate clients for climate data, because financed and insured emissions flow through their own disclosures. If your organization borrows from or is insured by a federally regulated institution, expect the request to reach you.

The CSA pause and what it means

In April 2025 the Canadian Securities Administrators paused work on a mandatory climate disclosure rule for reporting issuers, citing economic and competitiveness concerns and shifting global conditions. The pause means there is currently no securities-law requirement forcing broad mandatory climate disclosure on Canadian public companies.

It does not mean the direction reversed. The standards exist, they are being used voluntarily, and OSFI's regime is live. A pause is a delay in the mandate, not a retirement of it, and the data work required to comply does not get easier by waiting.

Global context: ISSB, SEC, and CSRD

Canada's standards do not exist in isolation. If you operate or raise capital internationally, several other regimes may reach you, and all of them share the GHG Protocol foundation.

The practical implication: if you build to the GHG Protocol and the ISSB baseline, you are aligned with CSDS, largely interoperable with OSFI, and positioned for CSRD and other regimes. Building to one common accounting base is far cheaper than reconstructing your numbers for each framework separately.

What to prepare now

1. Build a complete inventory of your energy accounts and meters across every site, including tenant and leased spaces. You cannot disclose what you have not counted.
2. Establish clean Scope 1 and Scope 2 activity data from your utility bills, with each figure traceable to a source document.
3. Screen your Scope 3 categories for materiality so you know where the largest indirect emissions sit before Scope 3 relief expires.
4. Choose and document Canadian emission factors by province and vintage, so your numbers are defensible and restatable.
5. Stand up governance and a repeatable process now, so the first mandatory report is a formality rather than a fire drill.

How MartinAI helps

Every framework in this landscape, CSDS 2, OSFI B-15, and ISSB S2, resolves to the same requirement: gross emissions measured under the GHG Protocol from clean, traceable activity data. MartinAI reads utility bills across every commodity and format, validates them, and produces structured activity data for Scope 1 and Scope 2 emissions, with each number traceable back to the originating bill.

That means your disclosure preparation is not framework-specific busywork. Build the measured base once, and it feeds voluntary CSDS reporting, OSFI-driven data requests from your bank or insurer, and any international regime that reaches you, all from the same audit-ready source. MartinAI focuses on the data foundation, the part that is hardest to fake and most expensive to reconstruct later.

The takeaway

Canada's climate disclosure picture is layered: CSDS is voluntary but expected, OSFI B-15 is mandatory for financial institutions and reaches their clients, and the CSA rule is paused rather than gone. The common denominator is GHG Protocol emissions from clean data. Build that foundation now and you are ready for whichever requirement lands first, in whatever order.