Canadian public issuers grappling with the impact of the
COVID-19 pandemic on their businesses are rightly focusing on the
health and safety of their workforce and customers, business
continuity and risk management. However, while balancing these and
the many other critical issues flowing from this pandemic, issuers
must also contend with their public disclosure obligations.
At this stage, the uncertainty around the magnitude and duration
of this pandemic may make it impractical for most issuers to
quantify its impact on their businesses, even for issuers that have
already suffered a direct, material impact. However, it is becoming
increasingly likely that the impact ultimately will be material for
most issuers. As a result of this uncertainty, Canadian public
issuers will need to decide almost in real time what to disclose
regarding the pandemic's implications for their businesses, and
when to disclose it, in order to satisfy their disclosure
obligations.1 In making
