The Office of the Superintendent of Financial Institutions (OSFI) has announced an update to delay its climate-related financial disclosures by 3 years. In a letter to the industry, OSFI provided updates on Guideline B-15: Climate Risk Management, which applies to federally regulated financial institutions, including banks and insurance companies, for the disclosure of Scope 3 greenhouse gas emissions. This delay in the guideline gives private market firms, asset managers, and impact investors additional time to align their climate-related disclosures and strategies. 

Let's explore the updates on emissions reporting by OSFI in detail.

About the Guideline B-15: Climate Risk Management

Introduced by OSFI in March 2023, Guideline B-15 is a set of rules or a framework that is designed to enhance the resilience of Federally Regulated Financial Institutions (FRFIs). It focuses on managing both the physical and transition risks involved with moving towards a low-emissions economy. The guideline emphasizes that FRFIs should integrate climate risk considerations into their operational and strategic frameworks. 

One of those considerations is disclosing Scope 3 emissions, and based on initial guidelines the companies were under obligation to disclose this for 2025 financial year. However, the timeline for Scope 3 emissions is now pushed back by three years to begin 2028. 

“Although the alignment with the CSSB provides additional transition relief for the disclosure of Scope 3 greenhouse gas emissions, we expect federally regulated financial institutions to continue to make progress in understanding, measuring, and managing their climate-related risks in accordance with the expectations in Guideline B-15.” — said OSFI on the update. 

Key updates on the Guidelines B-15: Climate Risk Management

• The OSFI revised the implementation date of the guideline for the disclosure of Scope 3 greenhouse gas emissions. As mentioned above, the timeline is delayed by 3 years (fiscal year 2028) to align with the Canadian Sustainability Standards Board (CSSB) standards.
• Next, the regulatory body of Canada has clarified the expectations for on-balance sheet and off-balance sheet assets under management. 
• The implementation date is set for fiscal year 2029 for the Scope 3 greenhouse gas emissions of the off-balance sheet assets under management.

Next steps

The updates on the Guideline B-15 disclosure expectations will be included in the next iteration of the frameworks in March 2025. Furthermore, the expectations for the Climate Transition Plans and Scenario Analysis have been unchanged.

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