Large Employer Emergency Financing Facility Requires Climate-related Financial Disclosure


The federal government's recently announced Large Employer Emergency Financing Facility (LEEFF), part of Canada's COVID-19 Economic Response Plan, will require borrowers to publish annual climate-related financial disclosure reports in compliance with the recommendations issued by the Task Force on Climate-related Financial Disclosures (TCFD). Disclosure will be required to highlight how borrowers' corporate governance, strategies, policies, and practices will:


  • help manage climate-related risks and opportunities; and

  • contribute to achieving Canada's commitments under the Paris Agreement and net-zero by 2050 goal.


The TCFD recommends disclosure in four core areas:


  1. Governance. Disclose the organization’s governance around climate-related risks and opportunities.

  2. Strategy. Disclose the actual and potential impacts of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning where such information is material.

  3. Risk Management. Disclose how the organization identifies, assesses, and manages climate-related risks.

  4. Metrics and Targets. Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities where such information is material.


LEEFF will provide short-term liquidity assistance in the form of interest-bearing term loans to large Canadian employers that have been affected by the COVID-19 outbreak. The program will be available to large Canadian employers that (a) have a significant impact on Canada’s economy (as demonstrated by (i) having significant operations in Canada or (ii) supporting a significant workforce in Canada); (b) can generally demonstrate approximately $300 million or more in annual revenues; and (c) require a minimum loan size of $60 million. Canada Enterprise Emergency Funding Corporation (CEEFC), a subsidiary of Canada Development Investment Corporation (CDEV), will deliver the program in cooperation with Innovation, Science and Economic Development Canada (ISED) and the Department of Finance. For additional information, please contact Lisa DeMarco at lisa@demarcoallan.com.

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