Climate-related Financial Disclosure Requirements to Access the New Federal Economic Stimulus Fund: Large Employer Emergency Financing Facility (LEEFF) Program

On May 11, 2020, the Government of Canada announced the Large Employer Emergency Financing Facility (LEEFF) program as part of its COVID-19 Economic Response Plan. While the government is still in the final stages of establishing the LEEFF program, it has specified the eligibility to be large for-profit-businesses and certain not-for-profit businesses with annual revenues greater than $300 million.

To have access to the LEEFF, large companies will not only be required to meet the usual criteria (respect union agreements, protect workers’ pensions, adhere to rules around share buy-backs and the salaries and bonuses of top executives), but also be required to commit to publish annual climate-related financial disclosure reports consistent with the Task Force on Climate-related Financial Disclosures (TCFD). This announcement is noteworthy since emergency funds rarely come with such requirements. Moreover, it is meaningful because it shows Canada’s strong commitment to meet its emissions targets and sends a clear signal to the Canadian companies to set their foot in the right path.

Globally, the TCFD has been gaining traction throughout all sectors from collaborative efforts of WBCSD organizing sector-specific Preparer Forums and the Corporate Reporting Dialogue aligning standards and reporting with the TCFD’s recommendations. In the beginning of this year, the world’s largest asset management firm, BlackRock, announced that sustainability will be the firm’s new standard for investing and released a public letter addressed to companies it invests in to disclose climate-related risks.

More Background of Task Force on Climate-related Financial Disclosures (TCFD) can be found here.

 

TCFD

Task Force on Climate-related Financial Disclosures (TCFD)

At the COP21 Paris Climate Change Conference in 2015, the Financial Stability Board (FSB) established an industry-led disclosure task force on climate-related financial risks under the chairmanship of Michael Bloomberg – the Task Force on Climate-related Financial Disclosures (TCFD). Since the establishment, the TCFD developed recommendations on climate-related financial disclosures in 2017 to help businesses disclose clear, comparable and consistent information about the risks and opportunities presented by climate change as well as promote and monitor adoption of its recommendations.