On Bay Street, sustainability leadership has moved from a branding exercise to a disclosure discipline that touches finance, legal, risk, and operations. That shift is visible in board agendas, analyst calls, and continuous disclosure calendars for TSX issuers. It is also why our Toronto recruiters are being asked to run searches for sustainability officers who can produce investor-grade reporting and lead real performance change, not just publish a glossy PDF.
Why TSX rules and OSC guidance are changing the profile
Two forces shape the talent demand. First, the Toronto Stock Exchange expects timely disclosure of material information under its policy and Company Manual. TSX’s own Guide to Timely Disclosure Requirements reminds issuers that material information must be released without delay and that the Exchange’s policy supplements securities law. National Policy 51-201 on Disclosure Standards makes a similar point about timely, balanced news and the duty to avoid selective disclosure. When climate risk, human capital, supply chain ethics, or environmental liabilities cross the materiality line, a TSX-listed company needs a leader who can surface facts quickly, vet them, and communicate them in language investors can use.
Second, the Canadian Securities Administrators have steadily clarified expectations. The CSA’s 2010 environmental guidance tells issuers how to approach environmental matters in continuous disclosure. Its climate disclosure project report from 2018 flagged gaps between investor needs and the filings of large TSX issuers. In 2019 the CSA issued Staff Notice 51-358 on climate-related risks, which did not create new law yet reinforced that material climate information belongs in public filings. “Boards are reading those notices and asking for audit-grade process owners rather than pure storytellers,” said Lamarche.
What changed since ISSB and the CSA’s 2025 update
In October 2021 the CSA opened consultation on proposed National Instrument 51-107, which drew on the TCFD structure and contemplated phased reporting of governance, strategy, risk management, and metrics and targets. The consultation notice explains the intent to improve comparability while acknowledging cost. Then, in April 2025, the CSA paused work on a new mandatory climate rule, while reminding issuers that existing law already requires disclosure of material climate risks. At the same time, Canada’s sustainability standard setter finalized CSDS 1 and CSDS 2, aligned with IFRS S1 and S2. The IFRS jurisdictional snapshot for Canada notes the standards are voluntary unless incorporated into securities law, and that they provide a practical framework issuers are encouraged to consider today.
The takeaway for hiring is simple. Whether or not a new national instrument is in force, companies still need leaders who can judge materiality, support MD&A and AIF disclosures, brief the audit committee, and coordinate timely news when a sustainability issue becomes market sensitive. “Investors expect structure, controls, and defensible assumptions, the same way they expect discipline in revenue recognition,” commented Lamarche.
How this shapes the sustainability officer’s remit
At TSX issuers, the role has shifted from report compilation to enterprise risk and disclosure management. The best candidates run a disclosure calendar that integrates with finance, legal, and operations, and they translate fast-moving technical topics into MD&A-ready language. They also maintain a live view of materiality, because a supplier event, enforcement action, or physical risk can turn into market-moving news that triggers TSX timely disclosure obligations.
- Build a defensible data program for greenhouse gas inventories, safety metrics, and human capital indicators, with traceable controls and version history.
- Own the cross-functional process for risk identification and board reporting, mapped to CSA 51-358 themes and NP 51-201 expectations.
- Prepare filings inputs for MD&A and AIF, and coordinate investor FAQs to avoid selective disclosure.
- Design playbooks for incident disclosure that align with the TSX timely disclosure guide and legal counsel direction.
- Benchmark against Canadian Sustainability Disclosure Standards so the company can scale to IFRS-aligned reporting if regulators move.
- Educate the business with short, plain-language guidance that reduces greenwashing risk and improves consistency across channels.
Profiles that work for Toronto-listed companies
Our shortlists increasingly blend three backgrounds. We see finance leaders who have owned internal controls, risk leaders who have worked under public scrutiny, and technically fluent operators who can simplify complexity without losing accuracy. Experience with audit or internal audit is valuable in a world where assurance is rising. Familiarity with TCFD and ISSB concepts helps, yet the real separator is fluency in materiality and continuous disclosure. Candidates who cite TSX expectations for “material information” and reference NI 58-101 corporate governance disclosure in board briefings tend to inspire confidence on Bay Street. “We look for leaders who can switch registers in seconds, from a controls discussion with the CFO to a site walk-through with operations,” Lamarche said.
How we run the search
We begin with problem definition. Do you need a builder who stands up a first-time program, or a scaler who turns a collection of KPIs into investor-grade reporting. We map stakeholders across finance, legal, investor relations, operations, procurement, and the board. That map shapes the competency model and the interview loop. Our screens include a disclosure case exercise where the candidate receives a hypothetical event and must draft a short board update, a press holding line, and an MD&A paragraph. We also ask for specific examples of materiality calls, including cases where the answer was to disclose nothing after analysis.
Reference work focuses on the candidate’s ability to integrate with disclosure controls. We probe how they collaborate with controllers, IR, and external counsel when information is incomplete and time is tight. We check their comfort level with trade-offs like scenario analysis scoping, Scope 3 estimation boundaries, and when to use external specialists. We do not expect every sustainability leader to be an engineer, but we do expect a command of concepts that are now routine in filings. The CSA’s sequence of notices, from 51-333 to 51-358, created a shared vocabulary. The right hire speaks that language and knows when something crosses into materiality under NP 51-201.
Compensation, reporting lines, and first-year goals
For non-venture issuers, we often place the role reporting to the CFO or General Counsel with a dotted line to the audit or risk committee. Base salary tracks senior functional leaders, and first-year incentives are tied to data quality, control design, and disclosure milestones rather than headline ratings. A common first-year goal is to publish a tighter, decision-useful sustainability section that aligns with the AIF and MD&A, with a clear policy for when sustainability issues trigger a news release consistent with TSX guidance.
Final thought for boards and CEOs
Regulators may adjust timelines, yet the market’s expectation for clarity has already shifted. The smart play is to hire a leader who treats sustainability as part of the issuer’s disclosure and risk architecture, not as a side publication. That hire pays for itself in fewer surprises, cleaner filings, and better conversations with investors. If you want help calibrating the role, “start by defining the decisions you expect this leader to enable,” commented Lamarche. “When the decision is clear, the profile writes itself and the search moves fast.”