Canada CSA Securities Administrators Brief
Headline
CSA publishes final-form NI 52-112 amendments ahead of IFRS 18 adoption, with a December 2026 target effective date
Executive Summary
The Canadian Securities Administrators (CSA) published final-form amendments to National Instrument 52-112. The amendments preserve existing non-GAAP and other financial measures disclosure obligations as IFRS 18 takes effect for annual periods beginning on or after January 1, 2027. The CSA launched the underlying consultation in November 2025.
Bottom Line
The CSA publishes final-form amendments to NI 52-112 that, subject to all necessary approvals, are to come into force on December 29, 2026. The amendments preserve NI 52-112 disclosure requirements for management-defined performance measures disclosed outside the financial statements once IFRS 18 takes effect, allow incorporation by reference to relevant financial statement notes to avoid duplication, and introduce a prominence requirement for additional subtotals disclosed outside the financial statements. Cresthaven reading: Canadian reporting issuers that disclose management-defined performance measures outside the financial statements face a pre-January 2027 compliance window to align their disclosure practices with both the amended NI 52-112 requirements and IFRS 18's own presentation rules.
Key Regulatory Signals
- Core Preservation of Non-GAAP Disclosure Obligations: The amendments address a structural question created by IFRS 18, which requires management-defined performance measures to be disclosed in a single note to the financial statements. The amendments allow those measures, which have historically been treated as non-GAAP financial measures, to remain subject to NI 52-112 requirements when disclosed outside the financial statements.
- Incorporation by Reference to Reduce Duplication: To avoid duplicative disclosure, the amendments allow certain information to be incorporated by reference to the relevant notes to the financial statements, under conditions the CSA specifies. Cresthaven reading: issuers that disclose management-defined performance measures both inside and outside the financial statements face a structural choice about where to carry the full disclosure and where to cross-reference.
- New Prominence Requirement for Additional Subtotals: The amendments introduce a requirement governing prominence when an additional subtotal is disclosed outside the financial statements. This aligns with IFRS 18's requirement that an additional subtotal presented on the face of a primary financial statement be displayed no more prominently than the totals and subtotals required by IFRS Accounting Standards.
- Conditional Effective Date of December 29, 2026: Subject to all necessary approvals, the amendments are to come into force on December 29, 2026, ahead of IFRS 18's effective date for annual reporting periods beginning on or after January 1, 2027. The BC Securities Commission did not participate in this release due to restrictions related to the upcoming B.C. provincial election.
Regulatory Delta
- NI 52-112 is Canada's codified framework for non-GAAP disclosure. - IFRS 18 is an IASB standard effective for annual periods beginning on or after January 1, 2027. The CSA has timed these amendments to be in force before that date, subject to all necessary approvals.
Materiality Classification
MEDIUM — Final-form amendments to a standing Canadian disclosure instrument with a conditional effective date of December 29, 2026, affecting reporting issuers that disclose management-defined performance measures outside the financial statements across participating CSA jurisdictions.
Time Horizon
effective — 2026-12-29
Intelligence Outlook
Monitor the CSA and participating provincial securities regulators for confirmation that all necessary approvals have been obtained and that this rulemaking comes into force as announced on December 29, 2026.