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Policy & Disclosure

CPP Investments splits C$787 billion portfolio by carbon intensity and governance

The new two-axis disclosure turns a carbon figure into a governance screen other allocators can adapt.

CPP Investments has added a second dimension to its climate reporting. The investment manager of the Canada Pension Plan said Aug. 20 it will classify individual holdings by carbon intensity and transition governance, producing a point-in-time view of where emissions sit across a C$787 billion portfolio. ESG Today reported the launch.

The carbon-intensity screen applies one threshold. For each holding, CPP measures Scope 1 and Scope 2 emissions in tonnes of CO2 equivalent. The denominator is $1 million of enterprise value including cash. A 40-tonne threshold flags assets in harder-to-abate industries and those with elevated carbon intensity relative to the rest of the fund. Government-issued securities sit outside the calculation, and the metric covers only Scope 1 and 2 emissions.

In the framework analysis, 86.7% of the portfolio as of March 31, 2026, came in below the 40-tonne line. That leaves 13.3% of the book on the other side, the slice the screen exists to surface. The number is a starting point, not a verdict. A company can clear the carbon line and still be unprepared for transition risk; a company above it can still be doing serious transition work.

Transition governance works as a gate. A holding is classified as confirmed if it meets at least one of three indicators: SBTi-approved targets, a TPI rating of Level 4 or 5, or participation in CPP's Decarbonization Investment Approach. The first two rely on outside judgment. The third relies on CPP's own engagement program.

Among confirmed holdings, approximately 83.5% cleared the gate through the two third-party indicators, SBTi and TPI; the remaining 16.5% were confirmed through the DIA. The split suggests independent scrutiny is carrying most of the classification weight. It also means the internal path is not a corner case: about one in six confirmed holdings got there through CPP's own approach.

The mix of evidence sources matters for allocators building a similar screen. SBTi and TPI produce external ratings that a portfolio manager can cite without relying on its own engagement team. The DIA is a different instrument; it rewards participation in CPP's own process, so the label partly measures engagement, not just the quality of a company's plan.

When the two screens disagree

The two dimensions will often conflict, and those are the useful cases. A low-carbon company without an approved target sits below the 40-tonne line but outside the confirmed category. A high-carbon company with SBTi approval sits above the threshold and in the confirmed column. The framework lets CPP separate the question of what a company emits today from the question of whether it is preparing for a lower-carbon economy.

CPP has reported portfolio carbon footprint metrics since 2018; the new framework wraps that data in a governance assessment. Richard Manley, the fund's chief sustainability officer, described the approach as disciplined underwriting, active ownership and a belief that the transition will unfold unevenly across sectors and regions. The framework, he said, stays consistent with the fund's mandate and climate change principles.

The ESG Today report does not detail what portfolio action will follow from the classification. As disclosure, the framework's value is to turn a carbon number into two questions: how much this holding emits, and whether it can show it is getting ready to emit less. Those are the questions worth copying.

Sources & further reading
ESG Today
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