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.
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 said the first submissions revealed recurring data-quality and reporting-discipline problems, and that it would use the early years of reporting to identify data gaps and amend the returns.
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 fossil fuels, transportation and 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.
OSFI found that about 77% of insurers' financed emissions came from corporate bonds, with fossil fuels accounting for roughly three-quarters of their Transition Vulnerable Sector emissions.
LINK TO GUIDELINE B-15
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.
OSFI said that, over time, as data quality improves and methodologies mature, financed emissions reporting will provide a robust foundation for stress testing, scenario analysis and supervisory dialogue, and that the standardised returns enable institutions to benchmark their own exposures against sectoral peers.