Proposed Diversity Disclosure for Banks

Summary#

The federal government published proposed Diversity Information Disclosure (Banks and Bank Holding Companies) Regulations under the Bank Act. The notice (published February 15, 2025) would require certain banks and bank holding companies to publish information about board and senior‑management diversity; the public can comment for 30 days after publication.

What it does#

• Requires distributing banks and distributing bank holding companies (as defined in the related distributing‑bank rules) to make specific diversity information publicly available.
• Asks boards to say whether they have term limits or other renewal mechanisms, and to describe them or explain why not.
• Asks whether the bank has a written policy to identify and nominate directors from designated groups, and if so to summarize the policy and report on measures and progress.
• Requires banks to report whether and how the board or nominating committee considers the representation of each designated group when selecting directors, and whether and how representation in senior management is considered when making appointments.
• Asks whether the bank has set targets (numbers or percentages) for each designated group on the board and in senior management, and to report progress toward those targets or explain why no targets were set.
• Requires counts and percentages for directors and senior management who belong to each designated group, including for all major subsidiaries. “Major subsidiary” is defined as a subsidiary that accounts for 30% or more of the parent’s consolidated assets or consolidated revenue on its most recent balance sheet or income statement.
• Treats First Nations, Inuit and Métis as separate designated groups and requires separate reporting for each.
• Provides a simple tabular form (a schedule) for reporting the numbers and percentages by group.
• Says the regulations would come into force when Division 40 of the Budget Implementation Act, 2024, No. 1 comes into force (or on registration if registered later).

Who's affected#

• Primarily distributing banks and distributing bank holding companies — the group of banks identified in the Distributing Bank regulations.
• Their boards of directors and members of senior management, because their diversity and policies are what must be reported.
• Major subsidiaries of those banks, since senior‑management figures for those units must be included.
• Investors, researchers, and members of the public who track corporate diversity and governance may use the new disclosures.
  If you want to know whether a particular bank is covered, the notice points to the existing definition of “distributing bank” in related regulations.

Why it matters#

• It would make standardized, comparable diversity data public for covered banks. That helps shareholders, job seekers, advocacy groups, and regulators see who is represented at the top of big banks.
• The rules push banks to document policies, targets and progress, which can increase accountability for improving representation of women, First Nations, Inuit, Métis, persons with disabilities, and visible minorities.
• It may change how banks recruit and report on leaders. It also creates a regular reporting task for affected banks.
• The measure is a proposal open for comment, not yet final.