Insurance Sector Diversity Disclosure Rules

Summary#

This is a proposed regulation published in the Canada Gazette, Part I on February 15, 2025 called the Diversity Information Disclosure (Insurance Companies and Insurance Holding Companies) Regulations under the Insurance Companies Act. It would require certain insurance companies and insurance holding companies to make detailed information about board and senior-management diversity publicly available, and the government is asking for comments for 30 days.

What it does#

• Says that two groups are in scope: distributing companies and distributing insurance holding companies (as defined in the Distributing Company and Distributing Insurance Holding Company Regulations).
• Requires those companies to publish information about how they handle diversity on their boards and in senior management, including:
  • whether the board has term limits or other renewal mechanisms, and why or why not;
  • whether there is a written policy to identify and nominate candidates from designated groups, and if so, a summary of the policy, steps taken to put it into practice, and progress toward its goals;
  • whether the board or its nominating committee looks at representation of each designated group when choosing director candidates, and whether that consideration is used for senior-management appointments;
  • whether the company has set targets (numbers, percentages, or ranges) and timelines for representation on the board and in senior management, and the progress toward those targets or reasons for not having targets;
  • the actual number and percentage of directors and senior managers who are members of each designated group, including for all major subsidiaries.
• Defines a major subsidiary as one that accounts for 30% or more of the company’s consolidated assets or consolidated revenue on the most recent balance sheet or income statement.
• Requires First Nations, Inuit and the Métis to be reported separately (they are treated as distinct designated groups for reporting).
• Provides a standard disclosure form (a schedule) that companies would use to report numbers and percentages.
• Ties the rules’ start date to the coming into force of Division 40 of Part 4 of the Budget Implementation Act, 2024, No. 1; if the regulations are registered after that day, they come into force on registration.

Who's affected#

• Distributing companies and distributing insurance holding companies (the notice points to another regulation for the exact definition).
• Boards of directors and members of senior management at those companies.
• Any major subsidiary of those companies (see 30% threshold above).
• It is not fully clear from this notice which specific firms will meet the “distributing” definition without checking the related Distributing Company regulations.

Why it matters#

• The rule would make more information public about who sits on insurance company boards and who holds senior roles. That can help investors, job-seekers, customers, and the public assess how companies are doing on diversity.
• Requiring targets and progress reporting may push companies to set clearer diversity goals and to track results.
• Separate reporting for First Nations, Inuit and the Métis highlights Indigenous representation specifically.
• Companies in scope will face new reporting work to collect and publish this data.
• This is a proposed regulation, not final law; comments are being invited for 30 days after the notice.