On February 20, 2025, the Office of the Superintendent of Financial Institutions (OSFI) announced updates to Guideline B-15 on Climate Risk Management, postponing certain climate-related disclosure obligations for federally regulated financial institutions (FRFIs). This insight summarizes and provides context to the Guideline B-15 updates.

Global convergence of standards

The updates aim to align with the Canadian Sustainability Standards Board's voluntary sustainability standards (CSSB Standards), released at the end of 2024. The CSSB Standards are similar to the International Sustainability Standards Board's standards from June 2023 and represent Canada's first generally applicable sustainability disclosure standards. As discussed here, the Canadian Securities Administrators (CSA) will also consider these standards in developing a climate-related disclosure rule under securities laws. The updates to Guideline B-15 are a step towards harmonizing Canada's sustainability and climate-related disclosure with global standards, while tailoring requirements to Canada's capital markets.

Guideline B-15 updates

Initially published in March 2023, Guideline B-15 set out minimum mandatory climate-related financial disclosures and timelines for implementation. Timeline for implementation varies based on the size and nature of the FRFI and the nature of the disclosure. Early mandatory disclosures include managing climate-related risks, climate-related targets, and Scope 1 and location-based Scope 2 GHG emissions, which is expected from Canada's largest banks within 180 days of the 2024 fiscal year end, and from smaller FRFIs within 180 days of the 2025 fiscal year end.

The Guideline B-15 updates postpones Scope 3 GHG emissions disclosures for all FRFIs from fiscal year end 2025 to 2028, aligning with the CSSB Standards' transitional periods. The CSSB Standards allow entities to omit Scope 3 emissions for the first three annual reporting periods starting on or after January 1, 2025, meaning the earliest required Scope 3 disclosures will be for the reporting period beginning on or after January 1, 2028.

These Guideline B-15 updates will be reflected in the next iteration of Guideline B-15, expected in late March 2025. Despite the postponement, OSFI expects FRFIs to continue progressing in understanding, measuring and managing their climate-related risks as outlined in Guideline B-15.

For more information on Guideline B-15 or other disclosure standards generally, contact Bill Gilliland and Heather Bonnell.

The authors would like to thank articling student Olivia Graham for her assistance with this article.