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ARTICLE · 02 DECEMBER 2021

Disclosure Obligations In The Covid-19 Era

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As the COVID-19 pandemic continues to cause considerable social and economic uncertainty, reporting issuers across all industries must remain diligent in disclosing the impacts of the pandemic...

CanadaCoronavirus (COVID-19)
Lara Jackson
Lara Jackson
Robert Sniderman
Robert Sniderman
Beth Burnstein
Beth Burnstein
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As the COVID-19 pandemic continues to cause considerable social and economic uncertainty, reporting issuers across all industries must remain diligent in disclosing the impacts of the pandemic – whether realized or anticipated – on their business operations, current financial condition, liquidity, and future prospects. The Canadian Securities Administrators (CSA) has indicated that they are committed to closely monitoring potentially misleading disclosure related to COVID-19,1 but over a year and a half into the pandemic, no Canadian securities regulator has announced charges against any reporting issuers for improper COVID-19 disclosure.

The CSA has conducted studies throughout the COVID-19 pandemic to review disclosure filings and analyze issuers' compliance with National Instrument 51-102 Continuous Disclosure Obligations. Most recently, the CSA published CSA Staff Notice 51-362 (SN 51-362), which summarized their findings and offered guidance on improved

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