Canada's Office of the Superintendent of Financial Institutions updated its climate risk Guideline B-15 on 7 March 2025, revising the framework to align with voluntary sustainability disclosure standards published by the Canadian Sustainability Standards Board in December 2024 and extending the deadline for Scope 3 greenhouse gas emissions disclosure to fiscal year 2028. The update gives federally regulated financial institutions additional time for Scope 3 disclosure, while leaving its other risk-management expectations unchanged.

Scope 3 emissions are those arising indirectly from a financial institution's financing activities and its wider value chain rather than from its own direct energy use and operations.

ALIGNMENT WITH CSSB STANDARDS

The CSSB published its voluntary Canadian sustainability disclosure standards in December 2024, drawing on the framework developed by the International Sustainability Standards Board and adapting it for the Canadian regulatory and corporate context. By aligning Guideline B-15 with these standards, OSFI establishes coherence between the requirements it imposes on federally regulated financial institutions and the broader, voluntary sustainability reporting standards available to Canadian companies.

OTHER EXPECTATIONS

Despite the extension of the Scope 3 disclosure deadline, OSFI said it expects institutions to keep making progress in understanding, measuring and managing climate-related risks under Guideline B-15; implementation dates for climate transition plan and scenario analysis disclosures remain to be determined, and Scope 3 disclosure for off-balance-sheet assets under management was set for fiscal year 2029. Financial institutions regulated by OSFI are still required to disclose the governance structures through which their boards and senior management oversee climate-related risks and opportunities, articulate strategies for identifying and managing climate risk across their portfolios, and conduct climate scenario analysis to assess the resilience of their business models under a range of warming and transition pathways.

Canadian banks and insurers now have until fiscal year 2028 to disclose Scope 3 emissions.