(a) Disclose:
(i) the issuer’s Scope 1 GHG emissions and the related risks, or the issuer’s reasons for not disclosing this information,
(ii) the issuer’s Scope 2 GHG emissions and the related risks, or the issuer’s reasons for not disclosing this information, and
(iii) the issuer’s Scope 3 GHG emissions and the related risks, or the issuer’s reasons for not disclosing this information.*
(b) disclose the reporting standard used by the issuer to calculate and disclose the GHG emissions referred to in (a).
(c) If the reporting standard referred to in (b) is not the GHG Protocol, disclose how the reporting standard used by the issuer is comparable with the GHG Protocol.
As an alternative, the CSA is also consulting on requiring issuers to disclose Scope 1 GHG emissions either a) when that information is material, or b) in all cases. Under this alternative, disclosure of Scope 2 and Scope 3 GHG emissions would not be mandatory. Issuers would have to disclose either their Scope 2 and 3 GHG emissions and the related risks, or the issuer’s reasons for not disclosing this information. Text reflecting this alternative disclosure requirement for Scope 1 GHG emissions in all cases is set out below.
GHG Emissions
(a) Disclose:
(i) the issuer’s Scope 1 GHG emissions and the related risks,
(ii) the issuer’s Scope 2 GHG emissions and the related risks, or the issuer’s reasons for not disclosing this information, and
(iii) the issuer’s Scope 3 GHG emissions and the related risks, or the issuer’s reasons for not disclosing this information.
(b) disclose the reporting standard used by the issuer to calculate and disclose the GHG emissions referred to in (a).
(c) If the reporting standard referred to in (b) is not the GHG Protocol, disclose how the reporting standard used by the issuer is comparable with the GHG Protocol.
* Lexata note: the disclosures required under (a)(i)-(iii) above are similar to the Recommendations of the Task-Force on Climate-Related Financial Disclosures (TCFD). The main difference is that, under the TCFD recommendations, companies do not have the option of explaining their reasons for not disclosing emissions as a substitute for actually disclosing emissions.