Report shows notable shift in disclosure practices as U.S. political pressures ripple north
For the first time in over a decade, Canadian public companies are pulling back on how much they disclose about their diversity, equity, and inclusion (DEI) initiatives.
The percentage of companies reporting on key diversity data points — such as the number and percentage of women on boards and in executive roles — tumbled compared to 2024.
This reversal comes after years of steady or increasing transparency, says the Osler report 2025 Diversity Disclosure Practices, citing “rapid and significant changes in the broader political, regulatory and business environment over the past 12 months,” such as pushback against DEI programs in the U.S.
“We have historically seen a stable-to-increasing percentage of companies reporting on the various data points required by the Diversity Disclosure Requirements. This year’s data reversed that trend. While overall compliance remains strong, we did observe a decline in the number of issuers reporting on particular data points this year,” says the report.
But, does this mean an overall focus on DEI in Canada is also facing a setback? We talk to two experts for their insights.
Reporting on DEI results
The proportion of Canadian issuers reporting on whether they considered the representation of women in making executive officer appointments declined “sharply,” according to Osler — by roughly 7.9% compared to last year.
Declines were also seen in the proportion of companies disclosing:
- if they have a written policy relating to the appointment of women to their boards (5.4%)
- if the company has a board diversity policy (4%)
- if they have adopted a target for the representation of women on the board (2.2%)
- if they have adopted a target for the representation of women among executive officers (2.2%).
There was a decline in the proportion of issuers that were providing disclosure on some of the metrics, says John Valley, partner and chair of corporate governance at Osler in Toronto.
“In particular, those that are non-numeric and relate more to policies and practices inside the organization.”
U.S. political climate shapes Canadian disclosure
Developments in the United States “had a clear impact in Canada,” says the Osler report, “with anecdotal evidence suggesting that many issuers actively considered and revised the nature and extent of their own diversity-related disclosures, particularly for those companies that are dual-listed or that have significant United States operational footprints.”
Executive orders and court decisions south of the border have prompted many Canadian companies — especially those with U.S. operations or listings — to become more cautious in their DEI communications, says Bill Gilliland, partner at Dentons Canada in Calgary.
“Companies have been increasingly careful to ensure they're complying with the mandatory requirements that they face by perhaps thinking more carefully about going above and beyond to tout other areas of DE&I where there are perhaps no requirements to make disclosure.”
In looking at DEI disclosure by public companies that have significant operations in both Canada and the U.S. over the last two years, there appears to be a “cutting back on non-mandatory disclosure in this space,” he says.
Furthering the argument is the “pause” by the Canadian Securities Administrators (CSA) back in April 2025 on changing DE&I disclosure requirements “to support Canadian markets and issuers as they adapt to the recent developments in the U.S. and globally.”
“It’s really premised on not pushing Canadian public companies to provide new disclosure in areas where there's sensitivity in some jurisdictions that they could be operating in,” says Gilliland.
Canada committed to DEI
Despite the drawback in DEI disclosure among Canadian companies, the driver for greater diversity, equity and inclusion is still strong, say both Valley and Gilliland – with good reason.
“For a number of issuers, and when we talk to institutional shareholders, they are still focused on diversity because they are looking at things like demographics and talent pipelines and wanting to ensure that they are identifying and developing the next generation of talent,” says Valley.
“Part of the reason business leaders continue to be focused on diversity-related initiatives is a concern about wanting to make sure that they are able to draw from the broadest possible talent pool, to identify the best-performing individuals.”
And that strategy is entirely consistent with the idea of merit-based hiring, he says.
“[Companies] are stopping and looking at [things like] ‘What is it we need to do long term? We want the best possible people. Well, are there things we need to do to help make sure that we are able to draw from the broadest possible talent pool?’”
New type of messaging around diversity
While disclosure rates have dropped, the two experts say the underlying commitment to DEI has not wavered. Instead, companies are reframing their messaging, focusing more on the business case for diversity
“We're going through a period where increasingly companies are focusing on really tying their efforts in this space generally to business reasons and strategic reasons and not relying on an assumption that all readers are aware of the general benefits that come from diversity, equity and inclusion,” says Gilliland.
Many companies are sensitive to changing, broader market and environment factors and political risk, says Valley, but consider DEI a key part of long-term business resilience and success.
“In other words… they may be changing how much they're saying and some of the nomenclature, they're not necessarily changing the core of what they're doing.”
Anecdotally, some of the disclosure around DEI has been more focused and emphasizes how diversity supports the business imperative, he says.
“People are taking a business-first approach to thinking about the disclosure.”
HR's role in boosting diversity
That focus on DEI makes a lot of sense, judging by Osler’s results showing the growth in women’s representation on boards has also decelerated. In 2025, women held 30.5% of board seats among TSX-listed companies, surpassing the 30% threshold for the first time but marking the smallest year-over-year increase — just 0.7 percentage points — since reporting began.
The proportion of women in executive officer roles remained flat, and representation of visible minorities, Indigenous Peoples, and persons with disabilities also stagnated.
HR professionals can play a key role in boosting those numbers, according to Valley.
“They can help to highlight for the broader leadership team the importance – from a talent-building perspective – of some of the diversity-related practices.”
While DEI practices may be the right thing to do, he says, HR can demonstrate that they are also needed because they drive important aspects of the firm's talent identification and development processes “that will help to maximize the breadth and depth of the talent pool that the organization has to identify its next generation of leaders and to continue to progress and capable people through the ranks throughout the organization.”
Gilliland says the role of HR leaders in driving DEI initiatives has always been there, but it’s more pointed now.
“If you're going to tell more of a story around why DE&I is important to a company – as opposed to simply showing statistics and data and articulating targets that are well-known within an organization – the messaging needs to be clearly… correct for all readers, including internal readers, obviously, of the disclosure,
“I think it's definitely an area that should be a focus if it's not in an organization, that's for sure.”
