Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The Canadian Bankers Association (CBA) appears to have been unsupportive of specific climate-related financial policy measures in Canada, advocating for decreased ambition in regulated corporate climate disclosure and climate-related banking policy.
Top-Line Messaging on Climate-Related Financial Policy: In a 2023 website post and pre-budget submission to the House of Commons, CBA supported a role for finance in delivering the goals of the Paris Agreement and meeting Canada’s net-zero by 2050 target. In a 2023 Hill article President and CEO Anthony G. Ostler advocated for continued investment in hydrocarbons for the “medium term.” In 2023 committee testimony CBA emphasized that climate-related policy changes should occur at the level of the real economy rather than the financial sector.
Position on Regulated Corporate Climate Disclosure: In 2023 comments to the International Sustainability Standards Board (ISSB), CBA advocated for the ISSB to work toward successful implementation of its climate disclosure standards across jurisdictions. In 2024 comments to the Canadian Sustainability Standards Board (CSSB) on its proposed transposition of ISSB standards, CBA advocated for flexibility around disclosure of emissions and transition plans, and asserted that scenario analysis disclosures should be delayed by two years. Later in 2024, however, CBA Director of Financial Stability Bryan Radeczy called for regulators to adopt the CSSB standards in his testimony to the Canadian House of Commons Standing Committee on Environment and Sustainable Development.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation:CBA has taken unsupportive positions in specific climate-related financial risk management policy discussions, opposing S-243 in 2023 testimony to the Canada Standing Committee on Banking. S-243 would require financial institutions to report on climate goals and alignment with 1.5C, set out guidelines for board membership, and direct the Office of the Superintendent of Financial Institutions to develop climate-adjusted capital adequacy guidelines. In 2023 comments to the Basel Committee for Banking Supervision (BCBS), CBA objected to the revision of core principles for banking supervision to include climate risk. In 2024 comments to the BCBS, CBA outlined objections to climate-related disclosure standards that are likely to inform prudential regulation, asserting that banks’ climate forecasts, physical risk exposure, and emissions are outside of Basel Pillar 3 disclosures which are intended to address financial risk and capital adequacy.
Position on Energy, Industry, and Land Transition: In a 2023 response to a Department of Finance consultation, CBA advocated for the removal of banks’ restriction from leasing light vehicles in order to increase electric vehicle use. In a 2024 Nova Scotia Pre-Budget submission, CBA appeared supportive of government investments and tax incentives to "create pathways to net zero" but advocated for a "flexible" approach to new regulation.