Response to CSA Consultation Paper 51-406 Modernizing the Regulation of Public Companies

We refer to the Canadian Securities Administrators (CSA)’s consultation on modernizing the regulation of public companies. We appreciate the opportunity to contribute our perspective.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank that manages the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As of 30 June 2026, we managed approximately CAD 3.3 trillion (USD 2.3 trillion) in assets, with CAD 106 billion invested in Canada. We held shares in 149 Canadian public companies with a combined value of about CAD 54 billion.

As a long-term, diversified financial investor, we rely on companies' disclosures to inform our investment decisions, risk management and shareholder voting. We have an interest in disclosure regimes that surface material, investor-relevant information in a consistent and comparable format, without imposing undue cost or duplication on reporting companies. We support the CSA's aim of a balanced and responsive regime that maintains strong investor protection and disclosure quality.

We highlight four points from our response. First, we support removing undue cost or duplication while retaining the material, consistent and comparable disclosures investors rely on for their decision-making wherever relief is applied. Second, consistent with our view on optimizing corporate reporting frequency, we support giving companies the option to report semi-annually, but suggest a measured approach, with appropriate safeguards to retain disclosure quality in and between filings. Third, we stress the importance of maintaining strong shareholder protections and regulatory stability through any modernization process to support a competitive Canadian market. Finally, we encourage the publication of a roadmap for aligning with the standards of the International Sustainability Standards Board (ISSB) for reporting financially material sustainability-related information.

Our responses to selected consultation questions are set out in Annex 1. They draw on our published positions and refer to our submissions to other regulators and standard-setters where relevant. We thank the CSA for considering our perspectives and remain at your disposal should you wish to discuss these matters further.

Yours sincerely,

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                            

Snorre Gjerde
Policy Lead