1. INTRODUCTION

As Canada moves towards achieving net-zero emissions by 2050 in a concerted effort to mitigate the worst consequences of climate change, a profound transformation is underway within the energy sector. This transition encompasses a wide spectrum of stakeholders, ranging from vertically integrated oil and gas conglomerates to independent power producers and utilities. They are confronted with an imperative task: to proactively address their expanding array of climate-related risks and change their business practices to align with economic opportunities associated with climate change and the net-zero transition.

Sound management of climate change-related risks and opportunities requires shared understanding and transparency on climate-related information, which must be facilitated by high-quality, reliable and comparable climate-related financial disclosures. With several jurisdictions moving ahead, Canada is poised to adopt mandatory disclosure of climate-related financial information for businesses. Canadian energy enterprises, characterized by their substantial size, stringent regulatory environment, and strong industry-regulatory engagement, will need to be prepared as Canada moves toward the implementation of these essential mandates.

As a starting point, energy companies need to understand their own data gaps and challenges. Better data would not only help these companies to complete their own climate disclosures but also disclosing along uniform standards will help improve data access and comparability of climate-related risks across Canada.

What are Climate-Related Financial Disclosures?

Climate-related financial disclosures are information that helps businesses and stakeholders analyze, quantify and integrate climate-related risks and opportunities into their decision-making and operating processes.^[1] This includes information on processes to manage climate-related risks and opportunities, current and future GHG emissions, net-zero/GHG emissions reduction targets, planned future investments in cleaner and more energy-efficient technologies, the ability to adapt to different climate change-related scenarios and more. In turn, these disclosures allow financial institutions such as banks, insurance companies, long-term institutional investors and others to analyze and factor in climate risks and opportunities and make better lending, insurance underwriting and investing decisions.

Most companies disclose climate-related information based on voluntary frameworks and guidance such as the recommendations from the Taskforce on Climate-related Financial Disclosures (TCFD). The four overarching elements of the TCFD recommendations include:^[2]

1. governance – describing the roles of the board and management in dealing with related opportunities and risks;
2. strategy – examining the actual and potential impact on the organization’s businesses, strategy and financial planning;
3. risk management – disclosing the processes used to identify, assess, and manage associated risks; and
4. metrics and targets – identifying the measures used to assess and manage climate-related risks and opportunities.

1.1 INTERNATIONAL PROGRESS ON CLIMATE-RELATED FINANCIAL DISCLOSURES

The adoption of voluntary frameworks has gained traction over the years. As per the TCFD Progress Report 2023, the percentage of companies disclosing TCFD-aligned information globally increased from 18 per cent in fiscal year 2020 to 58 per cent for fiscal year 2022.^[3] In Canada, among the companies which are part of the S&P/TSX Composite Index, 64 per cent adopted the TCFD recommendations for their climate disclosures, representing an increase of 113 per cent since the TCFD was implemented in 2019.^[4] However, voluntary disclosures lead to multiple and sometimes different reporting of information by the same firm, which in turn makes individual assessments and sector wide comparisons cumbersome. The lack of standardized reporting has also raised concerns about the reliability, usefulness, and comparability of such information.

To standardize reporting of sustainability and climate-related information, at the UN Climate Change Conference (COP26) in November 2021, the International Financial Reporting Standards Foundation (IFRS) announced the creation of the International Sustainability Standards Board (ISSB). The ISSB’s remit is to issue standards that deliver a comprehensive global baseline of sustainability-related financial disclosures building off the recommendations from the TCFD and other frameworks.^[5] In June 2023, the ISSB finalized its inaugural standards.^[6] IFRS S1 provides a set of disclosure requirements designed to enable companies to communicate their sustainability-related risks and opportunities they face over the short, medium, and long term. IFRS S2 focuses on the topic of climate and establishes how companies should disclose climate-related information.

While the sustainability standards are global, it is up to countries to implement mandatory climate-related financial disclosures in line with these standards. Countries such as the United Kingdom, China, New Zealand, Switzerland and others are moving forward on implementing mandatory disclosure requirements in line with the TCFD recommendations and now the ISSB standards.^[7] Mandatory disclosures will drive standardization for markets, reduce fragmentation and simplify the disclosure landscape for all stakeholders.^[8]

Some jurisdictions are proceeding more quickly than others. The European Union has adopted the European Sustainability Reporting Standards, subject to their Corporate Sustainability Reporting Directive, which will require all large companies and all listed companies (except listed micro-enterprises) to disclose information on risks and opportunities arising from social and environmental issues, and on the impact of their activities on people and the environment.^[9] The US Securities and Exchange Commission proposed rules requiring publicly listed companies to disclose climate-related information ranging from GHG emissions to expected climate risks to transition plans.^[10] However, the implementation of disclosure rules has been delayed to later in 2024 (April estimated).^[11] Pre-empting the federal rules, the state of California has put forward a law that will require certain public and private US companies doing business in the state to provide both quantitative and qualitative disclosures of GHG emissions and climate-related risks.^[12]

Climate-Related Financial Disclosures in Canada

The Government of Canada, alongside other G7 and G20 counterparts, has committed to moving towards mandatory disclosures aligned with the TCFD recommendations and now the ISSB standards.^[13] In Budget 2021, the Government of Canada announced that federal crown corporations will demonstrate climate leadership by adopting TCFD/ISSB recommendations as an element of their corporate reporting.^[14] The Office of the Superintendent for Financial Institutions (OSFI) has developed a principles-based climate risk management and disclosure requirement guideline for federally regulated financial institutions.^[15] The Canadian Securities Administrators (CSA) — the umbrella group for provincial and territorial securities regulators — has developed draft climate disclosure requirements for publicly listed Canadian companies.^[16] However, following the launch of the ISSB, the CSA is waiting to conduct further consultations to ensure it adopts disclosure standards consistent with ISSB standards.^[17] The Federal Government’s Fall Economic Statement 2023 also announced that the federal government will develop options for making climate disclosures mandatory for private companies in order to close the regulatory coverage gap for climate disclosures across the Canadian economy.^[18]

These developments suggest that mandatory climate-related financial disclosures are coming soon in Canada. Canadian energy companies need to take the necessary steps on climate disclosures to not only understand climate-related risks and opportunities within their operations but also access the much-needed capital and other financial services to undertake their own business transition to net-zero emissions by 2050 and be globally competitive.

2. CLIMATE DISCLOSURES NEED ADEQUATE CLIMATE DATA

Implementation Canada’s newly announced climate-related financial disclosure mandate will require energy companies to produce robust, high-quality, reliable climate data to ensure that climate disclosures provide decision-useful information. However, data gaps and challenges remain a critical barrier to progress on disclosures and Canada’s broader climate objectives.

To start, energy companies will need to understand where they might have data gaps and challenges and address them quickly to enable them to develop and complete their own climate disclosures. Moreover, by disclosing against uniform standards, energy firms (utilities in particular) have the potential to foster data uniformity on GHG emissions and climate-related transition risks for stakeholders in the Canadian economic landscape.

To understand data requirements, research undertaken by the Smart Prosperity Institute^[19] compares disclosure standards, frameworks and guidelines relevant to Canada. Amongst others, the relevant frameworks and regulatory instruments for energy companies include the TCFD’s Final Recommendations from the Task Force on Climate-Related Financial Disclosures^[20], ISSB’s IFRS S2 Climate-related Disclosures^[21] and CSA’s proposed National Instrument 51-107 Disclosure of Climate-related Matters^[22] for companies publicly listed in Canada.

The comparison of the relevant disclosure standards and regulations shows that businesses preparing disclosures require a mix of qualitative and quantitative data, information, methodologies, and forward-looking analysis based on the following broad pillars — governance, strategy, risk management, metrics & targets and transition planning and engagement strategies. Qualitative disclosures for governance, strategy, risk management and transition planning are specific to organizations preparing disclosures. On the other hand, quantitative disclosures rely on the development of commonly accepted metrics and targets and their underlying methodologies and assumptions.

The completion of quantitative disclosures is often the first step in the disclosure process. They feed into and supplement qualitative requirements and help decision-makers identify and analyze drivers, exposure, and financial impacts of climate-related risks and opportunities. For these reasons, businesses need to prioritize quantitative climate data to support disclosures.

Stakeholder consultations and desk research show consensus around the five types of quantitative climate-related financial disclosures that need to be prioritized:^[23]

• GHG Emissions – information, numbers, and methodologies for measurement and reporting of emissions across the value chains (Scope 1, 2 and 3, including financed emissions and insurance-associated emissions).
• Net Zero/GHG Emissions Reduction Targets – information and numbers needed to set net-zero/ GHG emissions reduction targets (e.g., interim emissions reduction targets).
• Physical Risk – information, numbers, and analysis to understand business activities or asset’s exposure and vulnerability to physical risks.
• Transition Risk – information, numbers, and analysis to understand business activities or assets exposure and vulnerability to the transition to a net-zero economy, resulting from policy, legal, market, reputation technological changes, or social adaptation.
• Scenario Analysis – methodologies, forward-looking analysis and results needed to assess physical and transition risks and opportunities.

For the five priority types of disclosures, the data requirements are assessed from the disclosure expectations in the TCFD recommendations/ISSB standards. The data needs for the five priority areas are listed below. It should be noted that some data, such as GHG emissions data, underpins multiple areas of climate-related financial disclosures. To assess and disclose transition risks, preparing entities first needs GHG emissions data to feed into the analysis and disclosure of net-zero/emissions reduction targets. Similarly, scenario analysis feeds into and relies on transition and physical risk data.

3. DATA GAPS AND CHALLENGES

The gaps and challenges for each of the five priority types of disclosures are summarized below:

GHG Emissions: Large entities, such as energy companies, seemingly have access to relevant activity data, emission factors and relevant guidance and methodologies to measure and disclose GHG emissions from their activities (Scope 1) and energy consumption (Scope 2). However, they are likely to face difficulty in accessing relevant and sufficiently granular data to measure and disclose emissions across their upstream and downstream value chains (Scope 3). Reasons range from preparing companies being unable to obtain information from value chain entities, value chain entities not being able to measure their activity consistently and accurately, complex corporate structures creating challenges in data collection, lack of supplier-specific emissions factors to calculate GHG emissions and value chain entities having different reporting timeframes resulting in significant reporting lags.^[24]

To fill the data gaps, preparers are likely to utilize a combination of supplier-specific activity data, where available, and broad sectoral-level physical or economic activity data with secondary emissions factors (industry averages) and/or information from third-party data providers.^[25] This quantification may involve subjective decision-making, disclosures and potential recalculation in subsequent years, thus leading to less reliable and comparable data. Similarly, recent research highlights complexities in applying methodologies and assumptions to measure and disclose Scope 3 emissions across upstream and downstream value chains negatively affect disclosures.^[26] Energy companies need to be aware of these data collection, analytical and quantification challenges to support their disclosures, especially concerning Scope 3, which is expected to be the majority of the corporation’s total GHG emissions.

Net-Zero/GHG Emissions Reduction Targets: GHG emissions reductions/net-zero targets are often disclosed by companies preparing disclosures. Preparing entities rely on estimations to fill data gaps related to GHG emissions measurement, which presents reliability and comparability challenges. To credibly set net-zero/GHG emissions reduction targets, preparing companies need to understand their sectoral pathway to achieve net-zero emissions.^[27] However, there are different approaches and trade-offs in analyzing sectoral pathways that create challenges in analyzing actions and outcomes at the entity level. In addition, lack of clarity regarding the application of existing frameworks and guidance on net-zero transition planning adversely impacts their development and, ultimately, disclosures.^[28] For energy companies, target setting is likely to be hindered for all three GHG emission scope levels, particularly Scope 3 emissions targets, due to the challenges described above.

Physical Risk: Physical risks such as climate-related heatwaves and floods can be significant and highly unpredictable. Energy companies need robust forward-looking data to account for and disclose these risks. Data on different types of physical hazards are available mostly from “off-the-shelf” datasets. These datasets may be expensive to procure and may not capture Canada-specific sub-national/regional physical risks at the spatial and temporal granularity required. These challenges create the need for granular, regularly updated, Canada-specific sub-national/regional physical hazard datasets.^[29] In addition to physical hazards, energy companies preparing disclosures need to analyze and disclose relevant information related to the exposure (likelihood of the severity of a hazard in a given place) and vulnerability (likelihood that assets will be damaged/destroyed/affected when exposed to a hazard) of operations and assets.^[30] There is limited availability of asset characteristics and location data to map location-specific exposures. Adaptive capacity data is not readily or uniformly available across sectors and is difficult to measure for preparers.^[31] There are no industry-specific physical risk metrics and targets, within an industry sector/sub-sector, against which a company can be benchmarked.^[32] There are also modelling challenges in assessing vulnerability from physical hazards, which makes it difficult to translate physical risks into economic impacts and disclose this information.

Transition Risk: Other things being equal, firms with higher emissions or less stringent emissions reduction or net-zero targets are expected to face higher transition risks.^[33] The main barriers to effective analysis and disclosures of quantitative transition risk are an incomplete measurement of Scope 1 and 2 emissions, limited availability of Scope 3 emissions, target setting for only narrow scopes of entities’ emissions and trade-offs in using different sectoral pathway approaches. There is a shortage of standardized metrics to appropriately assess transition risks, while data on transition preparedness are not always possible to disclose.^[34] In their absence, energy companies have to rely on third-party data providers who may fill the data and analytics gaps using their own models and assumptions, leading to incomparable and unreliable information for users of disclosures such as financial institutions.

Scenario Analysis: Models such as those developed by the Intergovernmental Panel on Climate Change (IPCC), the International Energy Agency (IEA), and NGFS, along with other guidance materials, are available to support preparers in undertaking and disclosing climate-related risks and opportunities under different scenarios. However, business-relevant data and tools that provide input to companies for conducting scenario analysis are less available. To fill these gaps, different organizations including energy companies have to employ subjective judgement or look towards expertise from external third-party data providers which may cause reliability and comparability challenges and negatively affect disclosures.

4. SUMMARY DISCUSSION AND FUTURE RESEARCH

Canada is moving forward on implementing mandatory climate-related financial disclosures across the economy. Good quality, comparable and reliable climate data is needed to move forward on climate disclosures. However, this report finds that different entities are likely to face different gaps and challenges across the five priority types of disclosures. Data availability varies across the five priority disclosure types and in cases where data is available, it may not be complete, comparable, and/or reliable. Energy companies are likely to have data to measure Scope 1 and 2 GHG emissions either directly with entities or through proxy estimations. They can also set absolute and/or intensity-based net-zero or GHG emissions reduction targets and interim targets. However, they are likely to face challenges in estimating and disclosing the full extent of their Scope 3 GHG emissions, translating existing sectoral transition pathways at the global level to set emissions targets at the entity level, developing transition-oriented metrics to provide forward-looking outlooks on climate-related transition risks and gathering business-relevant data inputs and tools to conduct scenario analysis.

To continually fill climate data gaps and address data-related challenges, greater coordination is needed amongst stakeholders such as federal provincial/territorial governments, regulators, standard-setters, statistical agencies/data providers, businesses, and financial institutions. Canadian energy companies — with robust industry-regulatory coordination — can lead from the front in coordinating with other stakeholders to support data availability and close the gap on reliability and comparability challenges. Some areas where regulators, including energy and securities regulatory bodies, and other stakeholders can coordinate are as follows:

• Regulators can work with other stakeholders such as governments and standard setters to continually update existing guidance on the use of granular emissions factors, activity data and/or proxies to calculate GHG emissions (particularly Scope 3 emissions) and restatement of emissions data. Additionally, these stakeholders can suggest uniform actionable steps across the sector if information is unavailable, and/or if new information and calculation methodologies become available.
• Regulators, governments, and statistical agencies/data providers can align to provide guidance and analytics support to energy companies on Canada-specific scenarios and pathways for sectors (e.g., oil & gas, utilities) to help translate sectoral transition pathways to entity-level emissions reduction pathways and facilitate net-zero/GHG emissions reduction target setting. These stakeholders can also collaborate to develop granular, easily accessible, regularly updated, Canada-specific sub-national/regional physical hazard datasets.
• Regulators, governments, financial institutions, and businesses can coordinate to develop standardized physical risk adaptive capacity and transition preparedness metrics to measure and track progress on both physical and transition risks for the energy sector.

As energy companies close their own data gaps and challenges, they can provide a path forward on data solutions for other sectors of the economy facing climate data-related gaps. For example, as per the recommendations of Canada’s Sustainable Finance Action Council (SFAC), Scope 1 and 2 GHG emissions quantification would be easier and more accurate if businesses had access to the emissions data associated with their energy and fuel consumption directly from their respective utilities/energy companies (as part of their utility bills).^[35] This process can result in marked improvements in the reliability and comparability of GHG emissions data across different entities and support other areas such as net-zero target setting and transition risk assessment. However, further analysis is needed to ensure that this works in practice, including practical challenges and associated costs that utilities/energy companies and regulators may face in making the data available.

At a higher level, it is also important to recognize that data requirements and disclosure standards, together with taxonomies, depend on and reinforce each other.^[36] Data, disclosure standards and taxonomies collectively form the interconnected building blocks of the climate information architecture.^[37] This architecture helps promote transparency, quantify climate-related risks and opportunities, and provide investors with clear and consistent information and signals to make financing decisions. However, future research needs to understand the challenges and opportunities that Canada’s energy sector will face in aligning with Canadian and global climate data, disclosure and taxonomy requirements and practices. This will help build a sustainable energy system that is truly aligned with Canada’s environmental and economic goals.

* Anik Islam is Senior Research Associate at the Smart Prosperity Institute. Colleen Kaiser, PhD is Program Director Governance and Innovation Policy at the Smart Prosperity Institute. Geoff McCarney is Assistant Professor of Environment and Development in the School of International Development and Global Studies, and Director of Research for the Institute of the Environment and the Smart Prosperity Institute.

1. “2022 Status Report” (October 2022), online (pdf): Task Force on Climate-related Financial Disclosures <assets.bbhub.io/company/sites/60/2022/10/2022-TCFD-Status-Report.pdf>.
2. Sean Cleary, “Why companies are getting on board with climate related disclosures” (2021), online: Institute for Sustainable Finance <smith.queensu.ca/centres/isf/resources/primer-series/financial-disclosures.php>.
3. “2023 Status Report” (October 2023), online (pdf): Task Force on Climate-related Financial Disclosures <fsb.org/wp-content/uploads/P121023-2.pdf>.
4. Millani, “Millani’s 7^th Annual ESG Disclosure Study: A Canadian Perspective” (October 2023), online (pdf): <66e92bb4-13f5-462a-98c4-69b0f2ad5f7d.usrfiles.com/ugd/66e92b_184f379cd39d4cbfa22c1e237478ae75.pdf>.
5. “Climate-related Disclosure” (June 2023), online: International Financial Reporting Standards <ifrs.org/projects/completed-projects/2023/climate-related-disclosures>.
6. “ISSB issues inaugural global sustainability disclosure standards” (26 June 2023), online: International Financial Reporting Standards <ifrs.org/news-and-events/news/2023/06/issb-issues-ifrs-s1-ifrs-s2>.
7. Jonathan Arnold, “More than Mandatory: Why Canada needs to go beyond global disclosure rules to secure its long-term economic success” (28 October 2021), online: Canadian Climate Institute <climateinstitute.ca/more-than-mandatory>.
8. Jennifer Fairfax et al.,“International Sustainability Standards Board releases draft sustainability and climate change disclosure proposals for public comment” (24 May 2022), online: Osler <osler.com/en/resources/governance/2022/international-sustainability-standards-board-releases-draft-sustainability-and-climate-change-disclo>.
9. European Union, “The Commission adopts the European Sustainability Reporting Standards” (31 July 2023), online: European Commission <finance.ec.europa.eu/news/commission-adopts-european-sustainability-reporting-standards-2023-07-31_en>.
10. U.S. Securities and Exchange Commission, “Enhancement and Standardization of Climate-Related Disclosures” (2022), online: <sec.gov/files/33-11042-fact-sheet.pdf>.
11. Maia Gez, Scott Levi, and Danielle Herrick, “Fall 2023 Reg Flex Agenda: Climate Rules Pushed to April 2024” (8 December 2023), online: Lexology <www.lexology.com/library/detail.aspx?g=9864456e-d723-4243-b1e4-13e7a14754b2>.
12. Deloitte, “California adopts legislation requiring climate disclosures” (11 October 2023), online: IAS Plus <iasplus.com/en/news/2023/10/california-climate-bills>.
13. “G7 Finance Ministers and Central Bank Governors’ Statement on Climate Issues” (12 October 2022), online: Government of Canada <canada.ca/en/department-finance/news/2022/10/g7-finance-ministers-and-central-bank-governorsstatement-on-climate-issues.html>.
14. “Budget 2021: A Recovery Plan for Jobs, Growth, and Resilience” (last modified 19 April 2021), online: Government of Canada <budget.canada.ca/2021/home-accueil-en.html>.
15. Office of the Superintendent of Financial Institutions Canada “B-15 Guideline: Climate Risk Management” (March 2023), online (pdf): OSFI <osfi-bsif.gc.ca/Eng/Docs/b15-dft.pdf>.
16. “Canadian Securities Administrators statement on proposed climate-related disclosure requirements” (5 July 2023), online: Canadian Securities Administrators <securities-administrators.ca/news/canadian-securities-administrators-statement-on-proposed-climate-related-disclosure-requirements>.
17. Ibid.
18. “2023 Fall Economic Statement” online (pdf): Government of Canada <budget.canada.ca/fes-eea/2023/report-rapport/FES-EEA-2023-en.pdf>.
19. Anik Islam, Colleeen Kaiser, and Marena Winstanley, “Climate Data Requirements, Gaps, and Challenges to Support Climate-Related Financial Disclosures” (August 2023), online (pdf): Smart Prosperity Institute <institute.smartprosperity.ca/sites/default/files/Climate%20Data%20Requirements%20Gaps%20and%20Challenges%20to%20Support%20Climate-Related%20Financial%20Disclosures.pdf>.
20. “Recommendations of the Task Force on Climate-related Financial Disclosures” (June 2017), online: Task Force on Climate-related Financial Disclosures <fsb-tcfd.org/recommendations>.
21. “IFRS S2 Climate-related Disclosures” (June 2023), online: International Sustainability Standards Board <ifrs.org/content/dam/ifrs/publications/pdf-standards-issb/english/2023/issued/part-a/issb-2023-a-ifrs-s2-climate-related-disclosures.pdf?bypass=on>.
22. Canadian Securities Administrators, “Consultation Climate-related Disclosure Update and CSA Notice and Request for Comment Proposed National Instrument 51-107 Disclosure of Climate-related Matters” (18 October 2021), at 74, online (pdf):<osc.ca/sites/default/files/2021-10/csa_20211018_51-107_disclosure-update.pdf>.
23. Supra note 19.
24. Emma Cox, and Casey Herman, “Tackling the Scope 3 challenge” (28 October 2022), online: PWC <pwc.com/gx/en/issues/climate/scope-three-challenge.html>.
25. Supra note 19.
26. Ibid.
27. Glasgow Financial Alliance for Net Zero, “Draft Recommendations for the Development of the Net-Zero Data Public Utility” (2022), online (pdf): <assets.bbhub.io/company/sites/63/2022/09/Development-of-the-Net-Zero-Data-Public-Utility-September-2022.pdf>.
28. “Metrics Targets and Transition Plans Consultations” (October 2021), online (pdf): Task Force on Climate-related Financial Disclosures <assets.bbhub.io/company/sites/60/2021/10/October_2021_Metrics_Targets_and_Transition_Plans_Consultation_Summary_of_Responses.pdf>.
29. Sean Cleary, and Simon Martin, “Partial Disclosure: Assessing the state of physical and transition climate risk disclosure in Canada” (October 2022), online (pdf): <smith.queensu.ca/centres/isf/pdfs/ISF-partial-disclosure-paper.pdf>.
30. Financial Stability Board, “The Availability of Data with Which to Monitor and Assess Climate-Related Risks to Financial Stability” (7 July 2021), online (pdf): <fsb.org/wp-content/uploads/P070721-3.pdf>.
31. Network for Greening the Financial System, “Progress report on bridging data gaps” (May 2021), online (pdf): <ngfs.net/sites/default/files/medias/documents/progress_report_on_bridging_data_gaps.pdf>.
32. Katherine Bakos, and Blair Feltmate, “Transitioning From Rhetoric to Action: Integrating Physical Climate Change and Extreme Weather Risk Into Institutional Investing” (July 2023), online (pdf): Intact Centre on Climate Adaption <intactcentreclimateadaptation.ca/wp-content/uploads/2023/07/UoW_ICCA_2023_07_Integrating_Physical_Climate_Change_Risk_Into_Investing.pdf>.
33. Supra note 19.
34. Supra note 30.
35. Sustainable Finance Action Council, “SFAC recommendations to the Government of Canada on advancing climate-related disclosures in Canada” (2 February 2023), online (pdf): <canada.ca/content/dam/fin/programs-programmes/fsp-psf/SFAC-Disclosure-EN.pdf>.
36. Anik Islam, Colleen Kaiser, and Geoff McCarney, “Guiding Sustainable Finance Toward a Net-zero Future” (5 September 2023), online: Smart Prosperity Institute <institute.smartprosperity.ca/ClimateInformationArchitecture>.
37. Caio Ferreira, David L Rozumek, Ranjit Singh, and Felix Suntheim, “Strengthening the Climate Information Architecture” (8 September 2021), online: International Monetary Fund <imf.org/en/Publications/staff-climate-notes/Issues/2021/09/01/Strengthening-the-Climate-Information-Architecture-462887>.