Canada’s financial regulator, the Office of the Superintendent of Financial Institutions (OSFI), announced a new update to its climate-related financial disclosure expectations for banks and insurance companies, including a significant delay to the requirement for firms to disclose the emissions originating in their loan books and underwriting activities, which had been set to begin next year.

Released in March 2023, OSFI’s initial requirements for climate-related disclosures from federally regulated financial institutions begins reporting on fiscal 2024, starting with large institutions, followed by smaller firms the following year, with banks and insurance companies expected to report on a wide range of factors across governance, strategy, risk management, and metrics & targets. Key governance and strategy disclosure requirements include reporting on identified climate-related risks and opportunities, as well as how management assesses and the board oversees them, the impact of the risks and opportunities on the institution’s business and strategy, and a description of the institution’s climate transition plan.

The climate-related disclosure requirements also include reporting of Scope 1, 2 and 3 greenhouse gas emissions. Disclosures of operational Scope 1 and 2 emissions were also set to begin with fiscal 2024, while reporting on Scope 3 emissions, including financed and insured emissions, were slated to start a year later, with reporting beginning for 2025 for large institutions and 2026 for smaller firms.

In the new update, however, OSFI revised the implementation date of Scope 3 emissions reporting to begin for fiscal year 2028, three years after the initial expectation. The regulator explained that the update is being made to ensure that its guidance aligns with the recently released requirements of the Canadian Sustainability Standards Board (CSSB) standards.

The CSSB, which was formed to create Canadian Sustainability Disclosure Standards (CSDSs) largely aligned with the IFRS Foundation’s International Sustainability Standards Board (ISSB) standards were released in December 2024. While the ISSB standards included 1-year reliefs for reporting on Scope 3 emissions, however, the CSSB extended this relief to 3 years.

In addition to extending the timeline for financed emissions, OSFI’s update also included an implementation date for the disclosure of off-balance sheet emissions, such as those from capital markets activities, with reporting set to begin on fiscal year 2029.

In its update, OSFI said:

“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.”