Diversity Disclosure for Insurance Companies

Summary#

These are proposed Diversity Information Disclosure (Insurance Companies and Insurance Holding Companies) Regulations published on February 15, 2025 under the Insurance Companies Act. If adopted, they would require certain publicly distributing insurance companies and their holding companies to publish information about board and senior‑management diversity, including counts, percentages, policies, targets and progress. Interested parties may comment within 30 days of publication.

What it does#

• Applies to distributing insurance companies and distributing insurance holding companies (the type that sell shares to the public).
• Requires directors to make public a range of diversity information, including:
  • whether the board has term limits or other renewal mechanisms, or why not;
  • whether the company has a written policy to identify and nominate candidates from designated groups (as defined in the Employment Equity Act), or why not;
  • a summary of that policy’s objectives and key points, how it is implemented, and the company’s annual and cumulative progress;
  • whether the board or nominating committee considers representation of designated groups when selecting directors and senior managers, and how (or why not);
  • whether the company has set targets (numbers or percentages) and timelines for representation on the board and in senior management, and progress toward those targets;
  • the number and proportion (percentage) of directors and senior managers who belong to each designated group, including data for all major subsidiaries.
• Defines a “major subsidiary” as one whose assets or revenue account for 30% or more of the company’s consolidated assets or revenue.
• Requires First Nations, Inuit and Métis to be reported separately.
• Provides a simple disclosure form in the regulations for reporting the counts and percentages.
• The notice invites comments to Manuel Dussault, Director General, Financial Institutions Division, Department of Finance, using the Canada Gazette online comment tool or other means (see the Gazette notice) within 30 days after publication.

Who's affected#

• Distributing insurance companies and distributing insurance holding companies (publicly listed insurers and their holding companies).
• Their boards of directors and senior management, because the regulations ask for policies, targets and reporting on those groups.
• Major subsidiaries of those companies (because their senior‑management numbers may be included).
• Stakeholders who follow or use corporate disclosure: investors, shareholders, regulators, advocacy groups, and employees.
• Indigenous communities named in the rules: First Nations, Inuit, Métis (their representation must be reported separately).

Why it matters#

• It would increase public transparency about who holds decision‑making roles in large, publicly distributing insurers.
• Investors and the public could use the data to compare companies on board and senior‑management diversity and to track progress toward stated targets.
• Companies may change recruitment, nomination and reporting practices to meet expectations or targets they disclose.
• The rule highlights Indigenous representation by requiring separate reporting for First Nations, Inuit and Métis.
• These are proposed regulations (not final). The rules say they come into force when Division 40 of Part 4 of the Budget Implementation Act, 2024, No. 1 comes into force (or on registration if that happens later).