Canadian Securities Administrators seeks feedback on pitched disclosure changes

The amendments impact disclosure requirements for non-GAAP and other financial measures
Canadian Securities Administrators seeks feedback on pitched disclosure changes

The Canadian Securities Administrators is seeking feedback on pitched modifications to National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure (NI 52-112) and other materials.

The changes mainly aim to ensure that measures which were under NI 52-112 requirements remain in place after the new International Financial Reporting Standards (IFRS®) Accounting Standard, IFRS 18 Presentation and Disclosure in Financial Statements, was adopted.

IFRS 18 takes effect for annual reporting periods starting on January 1, 2027. Under this standard, management-defined performance measures must be disclosed in one note to the financial statements. Such measures are defined as income and expense subtotals intended to present management’s perspective on financial performance to investors.

If the proposed amendments are not effected, such measures, which have generally been considered financial measures that are not generally accepted accounting principles, would not be subject to NI 52-112 disclosure requirements when disclosed outside of financial statements.

The CSA said the pitched changes permit incorporation by reference of certain information to the relevant notes to the financial statements in specific situations, avoiding duplicative disclosure.

“The CSA recognizes the need to consider the changes resulting from IFRS 18 as it relates to securities regulation. The Proposed Amendments help avoid duplicative disclosure, which minimizes regulatory burden for Canadian issuers,” said Stan Magidson, CSA chair and Alberta Securities Commission chair and CEO, in a statement.

The amendments also introduce a prominence-related requirement when an additional subtotal is disclosed outside the financial statements. This better connects it to IFRS 18, which requires an additional subtotal presented on the face of a primary financial statement to be no more prominent than IFRS Accounting Standards-required totals and subtotals.

The CSA will close the consultation on February 11, 2026. It listed the proposal details in a Notice and Request for Comment that has been published on the websites of CSA members.