The Office of the Superintendent of Financial Institutions published its insights from the first-ever Climate Risk Return submission cycle on 20 November 2025, marking the completion of an inaugural data-collection exercise involving Canada's six domestic systemically important banks and four internationally active insurance groups. The CRR was introduced by OSFI in March 2024 as a standardised supervisory tool, and this initial cycle represents the first time the regulator has assembled a comprehensive, consistent dataset on financed greenhouse-gas emissions across the country's most significant financial institutions.
The aggregate financed emissions reported by the six D-SIBs stood at approximately 301 megatonnes of carbon dioxide equivalent, while the four IAIGs contributed approximately 58.2 MtCO2e, bringing the combined total across banks and insurers to around 360 MtCO2e. OSFI described the figures as an important baseline from which to track changes in the emissions profiles of supervised institutions over successive reporting cycles, emphasising that the exercise is diagnostic rather than immediately prescriptive.
TRANSITION VULNERABLE SECTORS DOMINATE EXPOSURE
A significant portion of the reported financed emissions is concentrated in sectors that OSFI classifies as Transition Vulnerable — industries such as oil and gas, heavy manufacturing, and certain areas of agriculture that face potentially substantial business-model disruption under various climate-transition scenarios. Fifty per cent of bank financed emissions and 67% of insurer financed emissions were found to be tied to these sectors, indicating a material degree of transition risk embedded in the balance sheets and investment portfolios of Canada's largest financial institutions.
The higher concentration of Transition Vulnerable Sector exposure among insurers compared with banks reflects the composition of the investment portfolios that insurance companies hold to back their long-duration liabilities. Insurers typically hold substantial allocations to fixed income and equity in industries that have historically offered stable long-term cash flows — categories that overlap significantly with the sectors now classified as transition vulnerable. The CRR data allows OSFI to compare these concentrations across institutions and to engage with individual supervised entities about how they are managing the associated risks.
A FOUNDATION FOR FUTURE CLIMATE SUPERVISION
The CRR sits alongside OSFI's Guideline B-15 on climate risk management, which was introduced in 2023 and requires federally regulated financial institutions to develop their capacity to identify, measure, and disclose climate-related financial risks. Where B-15 establishes the qualitative governance framework for how institutions should approach climate risk, the CRR provides the quantitative supervisory data that allows OSFI to assess whether institutions are translating those risk-management commitments into measurable and consistent outcomes across the sector.
OSFI indicated that future CRR cycles will enable it to track trends across institutions and sectors over time, and that the insights published in November 2025 are intended to help participating institutions benchmark their own emissions data against the broader Canadian financial-sector picture. The regulator is expected to refine the CRR methodology in subsequent cycles based on feedback from D-SIBs and IAIGs, as well as in response to evolving international standards on climate-related financial disclosure. The inaugural publication represents a significant step in Canada's broader effort to integrate climate risk into the mainstream supervisory framework governing its banking and insurance sectors, and establishes a data baseline that will grow in value over successive annual cycles.