2025 Diversity Disclosure Practices

Introduction

Like last year, progress on enhancing diversity among the directors and executive officers of Canadian public companies lost momentum in 2025. The proportion of women on boards continued to increase in 2025, but at a far slower rate of growth — an increase of 0.7 percentage points, compared to an average of approximately two percentage points per year since we began reporting. This is the lowest rate of growth we have observed and is approximately half of the 1.3-percentage-point increase seen last year. There was essentially no change in the proportion of women executive officers compared to last year. For companies required to report under the CBCA Requirement, the representation of members of visible minorities, Indigenous Peoples and persons with disabilities on boards and in executive officer positions also remained essentially flat or, in some cases, regressed slightly from last year.

However, the representation of women on the boards of TSX-listed companies passed the 30% threshold for the first time (30.5%). Companies outside the S&P/TSX Composite Index drove the improvement this year, and this offset slight declines among the largest companies.

A changing environment...

Rapid and significant changes in the broader political, regulatory and business environment over the past 12 months have created challenges for diversity-related initiatives. This has been most notable in the United States following the issuance by U.S. President Donald Trump of several executive orders relating to DEI programs. These changes have resulted in many companies — especially those operating or listed in the United States — taking steps to reduce or reframe their communications surrounding DEI and in some institutional investors and proxy advisory firms revising their voting guidelines relating to diversity. However, shareholders still consistently and strongly opposed anti-DEI shareholder proposals this past proxy season in the United States (there were fewer such proposals in Canada overall), and it appears that many companies are quietly continuing many of their diversity initiatives.

...may be having an impact on disclosure...

These changes may have influenced the diversity disclosure practices of Canadian public companies in 2025. 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. There was a slight decline in the proportion of companies reporting on the number and percentage of women on boards and in executive officer roles this year, of 0.8–2% for each of these data points compared to mid-year 2024. The proportion of issuers reporting on whether or not they considered the representation of women in making executive officer appointments declined much more sharply — by approximately 7.9% compared to last year — with significant declines also being observed in the proportion of companies disclosing whether or not they have a written policy relating to the appointment of women to their boards (5.4%) and with respect to whether or not the company has a board diversity policy (4%), and smaller declines in the number of companies reporting on whether or not they have adopted a target for the representation of women on the board (2.2%) or among executive officers (2.2%). This trend is generally consistent among S&P/TSX Composite Index and S&P/TSX 60 companies as well, and is consistent with the anecdotal evidence that companies do appear to have made changes in their diversity disclosure this year, particularly for non-numerical descriptive disclosure provided in response to the Diversity Disclosure Requirement, such as disclosure of the objectives and key provisions of a company's policy on identifying and nominating women directors.

We also noted an overall decline of approximately 2.2% in the proportion of companies reporting whether or not they have a target for the representation of women on the board or in executive officer positions. However, among those continuing to provide disclosure, the number of companies disclosing that they had targets increased by 2.1 percentage points for directors (to 46%) and remained essentially flat for executive officers (to 10.8%).

...and on outcomes

The representation of women on boards of TSX-listed companies increased this year and the proportion of women directors across all TSX-listed companies exceeded 30% for the first time this year, at 30.5%. However, this represented an increase of only 0.7 percentage points compared to mid-year 2024, which is the lowest year-over-year increase we have seen since we began reporting 11 years ago. We also saw the rate at which women are appointed to fill new or vacant board seats continue to decline — down to 31.9% this year from 40.4% in 2024, and an even sharper decline from the historic high of 45.3% in 2023. Notably, the progress in the proportion of women directors this year was solely a result of the efforts of companies outside the S&P/TSX Composite, as S&P/TSX Composite companies and those in the S&P/TSX 60 both saw representation of women on their boards decrease (albeit slightly) for the first time — by 0.1 and 1.3 percentage points, respectively.

And consistent with the last number of years, we have seen essentially flat results among women executive officers and among the representation of members of visible minorities, Indigenous Peoples and persons with disabilities at both the director and executive officer levels.

Looking ahead

There is no question that the broader environment presents challenges to continued progress on diversity-related initiatives. As we observed last year, it appears that continued diversity progress will depend on companies recognizing the strategic value of enhancing their diversity-related practices and building a pipeline of capable diverse senior leaders.

There are signs that this is happening. The public statements relating to diversity may have changed, but anecdotal evidence and conversations with senior leaders of a range of Canadian public companies and institutional shareholders suggest they do in fact continue to view diversity as a strategic imperative in the continued war for corporate talent. But it is also clear that the political, regulatory and social landscape for continued progress is changing, and is no longer as favourable as it once was.

Highlights

8.5%

is the decline in the rate at which women are being appointed to fill new or vacant director positions of TSX-listed companies since last year

30.5%

of board seats among TSX-listed companies are held by women, compared to 38% among S&P Composite companies and 38.4% among S&P/TSX 60 companies.

10.8%

of TSX-listed companies have targets for women executive officers

9.6%

of the time the chair of a TSX-listed companyis a woman

7.9%

is the decline in the proportion of companies that disclosed whether or not they consider the level of representation of women in making executive officer appointments

5.5%

is the decline in the proportion of companies with a written policy relating to the identification and nomination of women directors

46%

of TSX-listed companies have targets for women directors and 30% is the typical target

Slight changes

in board representation for other diverse groups:

Visible minorities

10.7% in 2025 (10.2% in 2024)
Indigenous Peoples

1.1% in 2025 (1% in 2024)
Disabled persons

0.5% in 2025 (0.7% in 2024)

The Diversity Disclosure Requirement

The Diversity Disclosure Requirement requires disclosure

• whether or not the issuer has adopted a written policy relating to the identification and nomination of women directors. If the issuer has not adopted such a policy, it must disclose why it has not done so. If an issuer has adopted a policy, the issuer must disclose
  • a short summary of its objectives and key provisions
  • the measures taken to ensure that the policy has been effectively implemented
  • annual and cumulative progress by the issuer in achieving the objectives of the policy
  • whether, and if so how, the board or its nominating committee measures the effectiveness of the policy

• whether the issuer considers the level of representation of women on the board in identifying and nominating candidates for election or re-election to the board. If so, the issuer must disclose how and, if not, disclose the issuer's reason for not doing so.

• whether the issuer considers the level of representation of women in executive officer positions when making such appointments. If so, the issuer must disclose how and, if not, disclose the issuer's reason for not doing so.

• whether the issuer has adopted a target regarding the appointment of women to the board. If so, the issuer must disclose the target and the annual and cumulative progress of the issuer in achieving the target. If not, the issuer must disclose the reason for not doing so.

• whether the issuer has adopted a target regarding women in executive officer positions of the issuer. If so, the issuer must disclose the target and the annual and cumulative progress of the issuer in achieving the target. If the issuer has not adopted a target, it must disclose why it has not done so.

• the number and percentage of women on the issuer's board of directors.

• the number and percentage of the issuer's women executive officers, including all major subsidiaries of the issuer.

CBCA Requirement

The CBCA Requirement requires substantially the same disclosure as the Diversity Disclosure Requirement, but separately with respect to each "designated group" — which it defines to include, but not be limited to, designated groups as defined by the Employment Equity Act (Canada).

Accordingly, disclosure is required with respect to

1. women
2. Indigenous Peoples (First Nations, Inuit and Métis)
3. persons with disabilities
4. members of visible minorities

Companies subject to the CBCA Requirement may also elect (but are not required) to provide disclosure in respect of additional "designated groups" identified in their information circulars.

We recognize that there are a range of terms used to reference the various diversity characteristics referred to in this report. Different companies make different choices in this regard. Since our report is based on disclosure made by companies in response to legislated disclosure requirements, we have generally used the same terms as the legislation where applicable to avoid confusion. However, we have chosen to use the term "Indigenous Peoples" to include references to "Indians," "Inuit" and "Métis" Peoples covered by the term "Aboriginal peoples" in the legislation referenced by the CBCA Requirement.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.