Overview
Introduced: March 2023
Effective from: Fiscal periods ending on or after October 1, 2024
Last modified: May 2024
Region(s): Canada
About
Guideline B-15, issued by the Office of the Superintendent of Financial Institutions (OSFI), sets climate risk management expectations for Canada’s Federally Regulated Financial Institutions (FRFIs). It aims to ensure that financial institutions are resilient in the face of both physical and transition risks related to climate change.
Rooted in the four pillars of the TCFD framework (Governance, Strategy, Risk Management, and Metrics & Targets), B-15 outlines how climate-related risks must be integrated into core business and risk frameworks. It also mandates robust, transparent climate disclosures that reflect both near-term risks and longer-term strategic impacts.
Criteria for compliance
Federally Regulated Financial Institutions (FRFIs) headquartered in Canada, including:
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Banks and bank holding companies
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Trust and loan companies
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Life and health insurance companies
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Property and casualty insurers
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Cooperative credit associations
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Internationally active insurance groups (IAIGs)
Excluded:
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Foreign bank branches and foreign insurance branches operating in Canada
Compliance timelines
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October 1, 2024: First phase of mandatory disclosures begin for fiscal periods ending on or after this date. Includes Scope 1 and 2 emissions, governance, strategy, risk management practices, and climate metrics.
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October 1, 2025: Full compliance required, including disclosure of Scope 3 GHG emissions and expanded expectations for transition risk planning.
Disclosure requirements
FRFIs must disclose climate-related information aligned with the following four pillars:
Governance
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Role of the Board and Senior Management in overseeing climate-related risks
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Internal accountability structures, roles, and climate oversight integration
Strategy
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Identified climate-related risks and opportunities across short, medium, and long-term timeframes
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Business and financial impact of climate-related risks and opportunities
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Resilience testing, including scenario analysis aligned with 1.5°C and 2°C pathways
Risk management
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Methodologies for identifying, assessing, and managing climate-related risks
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Integration of climate risks into overall enterprise risk management (ERM) frameworks
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Emerging climate scenario modeling and stress testing practices
Metrics & targets
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GHG emissions disclosures for Scope 1, Scope 2, and from 2025 onward, Scope 3
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Use of emissions intensity metrics and financed emissions disclosures (as applicable)
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Climate-related targets and tracking mechanisms for progress
Third-party auditing
While not currently mandatory, OSFI strongly encourages FRFIs to implement internal governance processes that mirror the standards used for financial reporting. Future versions of B-15 may introduce formal external assurance expectations for climate disclosures, particularly for larger institutions.
Penalties for non-compliance
As the national regulator, OSFI has full supervisory authority to enforce B-15. This includes:
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Issuing supervisory letters or orders
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Requiring remediation plans
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Imposing fines or restrictions for systemic noncompliance
Non-adherence could also result in reputational damage and reduced investor confidence in climate governance.
