Companion Policy to National Instrument 52-109 Certification of Disclosure in Issuers' Annual and Interim Filings
Part 11 Reporting Changes in ICFR
Section 11.1

Assessing the Materiality of a Change in ICFR

Paragraph 7 of Form 52-109F1 and paragraph 6 of Form 52-109F2 require an issuer to disclose any change in the issuer’s ICFR that has materially affected, or is reasonably likely to materially affect, the issuer’s ICFR. A material change in ICFR might occur regardless of whether the change is being made to remediate a material weakness (e.g., a change from a manual payroll system to an automated payroll system). A change in an issuer’s ICFR that was made to remediate a material weakness would generally be considered a material change in an issuer’s ICFR.