Responsible investment identification framework

Submission – CIFSC – Proposed Changes to CIFSC Responsible Investment Identification Framework

Recipients

Ms. Danielle LeClair, Chair
The Canadian Investment Funds Standards Committee (CIFSC)

Industry segments this resource supports

• Assets management
• Wealth management

Summary

We submitted comments to the CIFSC about proposed changes to the Responsible Investment (RI) Identification Framework. The submission supports aligning the framework with the revised CSA Staff Notice 81 334 and globally recognized definitions for responsible investment approaches. We recommend removing references to non regulated disclosure standards, maintaining ESG integration within the framework, and ensuring that the final framework reflects current regulatory expectations and real world investment practices. The submission emphasizes that removing ESG integration would create confusion, misrepresent market practices, and conflict with both Canadian regulatory guidance and global RI definitions.

Why this matters: Provides industry feedback to help ensure that the CIFSC Responsible Investment Identification Framework remains aligned with regulatory standards and global definitions, supporting clarity and consistency for investors and advisors.

Key takeaways

• We support aligning the framework with CSA disclosure guidance and global responsible investment definitions, as these are authoritative and widely recognized.
• We recommend removing references to the CFA Institute’s Global ESG Disclosure Standards, noting that they are not subject to regulatory oversight and could undermine the Framework’s credibility.
• We strongly oppose the proposal to remove ESG integration from the Framework, emphasizing that it remains a widely used and recognized responsible investment approach.
• The submission highlights that 202 out of 251 RI funds flagged by CIFSC use ESG integration and removing it would misrepresent the market and confuse investors and advisors.
• We note that ESG integration is recognized by the CSA and global definitions, and its removal would create inconsistency with regulatory expectations.
• The submission stresses that ESG integration is often used alongside other RI strategies and is fundamental to how many funds incorporate ESG considerations.

We encourage CIFSC to maintain alignment with existing regulatory standards rather than pre-emptively removing approaches that remain widely used and recognized.