Autorité des marchés financiers delays the application of certain climate-related disclosure requirements

On February 27, 2025, the Autorité des marchés financiers (AMF, Quebec’s financial services regulator) published for comments several proposed amendments to its “Climate Risk Management Guideline” (the Guideline). 

The proposed amendments would delay the application of certain climate-related disclosure requirements. The modified version of the Guideline is to come into force on March 31, 2025, and interested parties have until March 17, 2025, to submit their comments to the AMF.

The Guideline applies to financial institutions such as licensed insurers, financial services cooperatives, licensed trust companies and other licensed deposit-taking institutions under the AMF’s jurisdiction. It covers topics such as disclosure requirements, governance, risk management, scenarios and stress testing, capital requirements, fair treatment of clients and climate-related financial risk disclosure. For more information about the Guideline, please see our earlier publication.

The proposed amendments include a mention to the effect that financial institutions should not disclose commercially sensitive information regarding climate-related opportunities that could significantly compromise or harm their future economic benefits. However, if the financial institution does not disclose climate-related financial information as required by the Guideline, it should specify the elements it has not disclosed and explain the reasons for not disclosing them.

The Guideline’s implementation schedule would also be modified to postpone the application of certain disclosure requirements:

• the disclosure of financial institutions’ absolute quantity of greenhouse gas emissions is postponed from 2025 or 2026 to 2028;
• for financial institutions carrying out investment management activities, the disclosure of the absolute quantity of financed greenhouse gas emissions is postponed from 2025 or 2026 to 2029;
• the disclosure of certain industry-based metrics, as determined under the Canadian Sustainability Disclosure Standards 2, is postponed from 2025 or 2026 to 2028;

The other deadlines mentioned in the implementation schedule remain unchanged.

The amendments are proposed following the publication of the Canadian Sustainability Disclosure Standards 1 and 2, in December 2024, which provide certain reliefs regarding the timing of the application of reporting requirements. The Office of the Superintendent of Financial Institutions also indicated it will include similar deferrals in the application of its Guideline B-15 on climate risk management. These delays may be helpful for financial institutions that have yet to integrate the new reporting requirements into their existing compliance structures.