What is OSFI Guideline B-15?
By Nick Jang, founder of MINERVA Studio ·
The short answer
OSFI Guideline B-15, Climate Risk Management, sets out how federally regulated banks and insurers should govern and manage climate-related risks and what they should disclose about them. It was first published in March 2023; the current version, issued on 7 March 2025, aligns the disclosure chapter with the Canadian Sustainability Standards Board’s standards. The six domestic systemically important banks and Canadian-headquartered internationally active insurers started disclosing for fiscal 2024, everyone else for fiscal 2025, and Scope 3 financed emissions are due for fiscal 2028.
What B-15 asks for
Climate change reaches a bank or insurer in two ways. Physical risk is the flood that wrecks the houses behind a mortgage book, or the wildfire season that blows up a property insurer’s claims. Transition risk is the economy shifting away from carbon, which can leave a loan to a coal-heavy borrower worth less than it looked a year ago. B-15 asks institutions to treat both as real risks with owners, limits and numbers, not as a sustainability report written by the marketing team.
OSFI frames the guideline around three outcomes: the institution understands and mitigates the impact of climate risk on its business model and strategy; it has the governance and risk management to manage the risks it finds; and it stays financially resilient through severe but plausible climate scenarios, and operationally resilient through climate-related disasters.
Chapter 1: governance and risk management
The first chapter has five principles.
| Principle | What it means |
|---|---|
| 1. Governance | A clear governance and accountability structure for climate risk, with the board and senior management involved. |
| 2. Business model and strategy | Physical and transition risks are built into the business model and strategy, and the institution has a climate transition plan. |
| 3. Risk appetite | Climate risks are managed and mitigated in line with the risk appetite framework. |
| 4. Scenario analysis | Climate scenario analysis and stress testing assess the impact on the risk profile, strategy and business model over short, medium and long horizons. |
| 5. Capital and liquidity | Capital and liquidity buffers are sufficient for climate risks, assessed through the ICAAP or ORSA. |
Scenario analysis is where the work gets heavy. Scenarios should cover physical and transition risk and how the two interact, and OSFI points to the IEA, the IPCC and the NGFS for the scenarios themselves. It also requires institutions to take part in standardized climate scenario exercises and report the results, so every institution answers the same question in the same way at least some of the time.
Chapter 2: climate-related disclosure
The second chapter asks for public, annual climate disclosures that are relevant, specific, clear, reliable, proportionate and consistent over time. They’re due within 180 days of fiscal year-end and stay archived. The detailed content sits in Annex 2-2, which now follows the CSSB’s Canadian standards, themselves built on the ISSB’s IFRS S2. Emissions are measured with the GHG Protocol, and financed or insurance-associated emissions with the PCAF standard.
| Disclosure | D-SIBs and IAIGs headquartered in Canada | Other banks and insurers |
|---|---|---|
| Governance, strategy, risk management | 2024 | 2025 |
| Scope 1 and 2 emissions, targets | 2024 | 2025 |
| Cross-industry metrics | 2025 | 2026 |
| Scope 3, including financed and insurance-associated emissions | 2028 | 2028 |
| Industry-based metrics | 2028 | 2028 |
| Transition plan and scenario resilience disclosure | To be set by OSFI | To be set by OSFI |
OSFI moved Scope 3 to fiscal 2028 in February 2025 to stay in step with the CSSB, and called it transition relief. It also said the relief doesn’t pause the risk management work in Chapter 1.
How B-15 sits with the other guidelines
B-15 doesn’t stand alone. A climate-driven outage at a data centre is an E-21 question as much as a B-15 one. Climate stress results feed the capital assessment. And the models that estimate flood exposure or financed emissions are models like any other, so from 1 May 2027 they belong in the E-23 inventory with an owner, a rating and a review.
That last point catches people out. Climate models lean on long horizons, thin data and big assumptions, which is exactly the kind of uncertainty E-23 wants rated and written down. MINERVA keeps that inventory; see OSFI E-23 software.
Related questions
When did OSFI B-15 take effect?
For the six D-SIBs and internationally active insurance groups headquartered in Canada, from fiscal year-end 2024. For all other in-scope banks and insurers, from fiscal year-end 2025. Some disclosures, including Scope 3 emissions, are due for fiscal 2028.
Does B-15 require Scope 3 emissions disclosure?
Yes, from fiscal 2028 for every in-scope institution, including financed and insurance-associated emissions measured with the PCAF standard. OSFI moved the date from earlier years in February 2025.
Is B-15 aligned with ISSB?
Its disclosure chapter follows the Canadian Sustainability Standards Board’s standards, which are based on the ISSB’s IFRS S1 and S2, with Canadian transition relief.
Does B-15 affect capital requirements?
It asks institutions to hold sufficient capital and liquidity for climate risks and to include them in the ICAAP or ORSA. It doesn’t set a separate climate capital charge.
Do credit unions have to follow B-15?
Federally regulated institutions do. Provincially regulated credit unions follow their own regulator, though some provinces draw on OSFI’s approach.
Sources
- OSFI — Guideline B-15, Climate Risk Management
- OSFI — Letter to industry: updating Guideline B-15 for the final CSSB standards (20 February 2025)
- OSFI — OSFI issues final Guideline B-15 and responds to consultation feedback
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A plain-language explanation, not legal advice. The regulator’s own text is the source; read it, and take advice on how it applies to your institution.