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December 20, 2022

Issuers’ Disclosure in Uncertain Times: Canadian Securities Regulators’ Review of Public Disclosure


“It was the best of times, it was the worst of times,” said Charles Dickens in “A Tale of Two Cities”, accurately describing what it was like living and working through a pandemic, protests and unrest in 1859. Nearly two centuries later, public issuers found themselves in similarly tumultuous circumstances—managing the continuing effects of Covid-19 on global supply chains, grappling with rising interest rates and currency fluctuations, and navigating geopolitical conflicts such as the war in Ukraine. These challenges have ushered in a period of unprecedented uncertainty, prompting issuers to enhance their disclosures in financial statements, annual reports, and MD&As. The Canadian Securities Administrators (CSA) recognized that many issuers have significantly improved their disclosure efforts, yet noted recurring issues over the past two years. Common deficiencies include failure to properly apply specific IFRS requirements (such as revenue recognition or expected credit losses), insufficient forward-looking information in MD&As, and “greenwashing” of ESG-related disclosures.

This article outlines the CSA’s key findings, focusing on (i) Financial Statement Deficiencies, (ii) MD&A Deficiencies, and (iii) Other Regulatory Disclosure Deficiencies.

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