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Perception vs Reality: Behind the Headlines of Canadian ESG Investor and Disclosure Trends

November 28, 2025

Millani
ESG, Disclosure

Amid headlines suggesting retreat, parallel regulatory shifts in the United States and Europe, and rising legal scrutiny under Canada's Bill C-59, which introduces penalties for unsupported environmental or sustainability claims, Millani's analysis tells a more nuanced story. Corporate sustainability disclosure in Canada has remained remarkably stable, with continued, if more cautious, progress in key areas.
Our 9th annual ESG Disclosure Study examines how S&P/TSX Composite Index constituents are adapting their sustainability disclosures in response to shifting market conditions. In 2024, we observed the highest number of sustainability reports since 2022, despite the introduction of Bill C-59. Observations suggest that regulatory caution may have limited disclosure rates that would otherwise have been higher.
Read the full study here.
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TMX Newsfile
The end of the Section 16 exemption for foreign issuer directors and officers marks a major shift in SEC insider reporting. It introduces faster disclosure timelines and new transparency risks for global IR teams. Beginning March 18, 2026, directors and officers of Canadian and other foreign private issuers (FPIs) will be required to publicly report insider holdings and transactions under Section 16(a) of the U.S. Securities Exchange Act of 1934.
Supported by the Toronto Stock Exchange, the TSX Venture Exchange, and the BC Securities Commission, this course will give you the information you need to comply with Canada's complex system of securities regulation. Topics include fundamentals of corporate governance, securities law, shareholder communications and investor relations, financial statement requirements, obligations for company insiders, understanding TSX/TSX Venture Exchange requirements, and directors' powers, functions, and liabilities.