Physical climate risk data,
ready for CSDS and OSFI B-15.
The standard is here. The securities mandate is still paused. The prudential one isn't. The Canadian Sustainability Disclosure Standards (CSDS 1 and CSDS 2) follow the global ISSB baseline, voluntary for public issuers and mandatory in practice for the banks and insurers under OSFI Guideline B-15, where FY2026 brings the next set of disclosures into scope and extends Climate Risk Returns filing to the smaller institutions.
What changed in January 2026. OSFI deferred the financed-emissions expectation for off-balance-sheet assets under management to a future date and wound down its Climate Risk Forum, as part of a broader regulatory-efficiency push. The relief landed on emissions reporting. The guideline stayed, the disclosure timetable for everything else stayed, and the Climate Risk Returns still collect physical risk exposure by asset class and geography.
CSDS 1 and CSDS 2 are Canada's adoption of the global ISSB baseline (IFRS S1 and S2), with reliefs on Scope 3 and quantitative scenarios. Voluntary for public issuers: the CSA paused the mandatory rule on 23 April 2025 and has not restarted it. Mandatory in practice for federally regulated financial institutions under OSFI Guideline B-15, whose current version dates from 7 March 2025 and was last amended in January 2026.
Voluntary for all Canadian public issuers, though endorsed by Canadian institutional investors holding more than C$2.25 trillion. Mandatory under OSFI B-15 for around 350 federally regulated banks, insurers and trust companies (foreign bank branches excluded): D-SIBs and IAIGs from FY2024, other FRFIs from FY2025, with the cross-industry metrics landing FY2025 for the largest and FY2026 for everyone else. Scope 3 sits at FY2028; the off-balance-sheet AUM piece was deferred to a future date in January 2026.
CSDS 1 and CSDS 2: Canada's take on the global standard.
From the Canadian Sustainability Standards Board (CSSB), built on the International Sustainability Standards Board (ISSB) framework: IFRS S1 and IFRS S2, with Canadian transition reliefs. In effect since 2025, and now working through its first full disclosure cycles.
Voluntary for some. Mandatory in practice for the rest.
The Canadian Securities Administrators (CSA) paused the mandatory rule for public issuers. The Office of the Superintendent of Financial Institutions (OSFI) didn't pause its own, and where relief has come, it has landed on emissions reporting rather than on physical exposure.
Mandatory for the financial sector.
Around 350 federally regulated banks, insurers and trust companies are inside the B-15 reporting cycle, and FY2026 is the year the cross-industry metrics reach the smaller institutions and the standardised Climate Risk Returns extend to them too.
C$2.25tr of AUM endorsed it.
Ten of Canada's largest pension and asset managers, representing more than C$2.25 trillion, publicly backed the final CSDS standards when they were issued. That expectation outlived the CSA's decision to stop work on the rule.
The physical questions stayed.
January 2026 brought a deferral of the off-balance-sheet AUM financed-emissions expectation and the wind-down of OSFI's Climate Risk Forum. What it did not touch: the strategy, risk management and metrics disclosures, the scenario analysis expectation, or the Climate Risk Returns that ask where your exposed assets are.
The CSDS framework: 7 chapters built on the ISSB baseline.
CSDS 2 follows the four pillars from the Task Force on Climate-related Financial Disclosures (TCFD), with explicit greenhouse gas (GHG) metrics, scenario analysis and Scope 3 expectations. OSFI B-15 enforces the same shape for FRFIs, on its own phased timetable.
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Chapter 1: Governance
The board owns the risk.
CSDS 2 follows TCFD on governance: disclose the body or individuals with oversight, how climate factors into their work, and management's role in the day-to-day. OSFI B-15 expects the same, plus a documented senior accountability trail.
- Identify the board, committee or individual with climate oversight
- Show how climate is integrated into strategy, risk and major decisions
- Describe management's role: who reports to whom, with what frequency
- For FRFIs: senior accountability under OSFI B-15 with documented controls
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Chapter 2: Strategy
Asset by asset, horizon by horizon.
Disclose the climate-related risks and opportunities that could reasonably affect prospects, the actual and anticipated effects on business model and strategy, and the financial position over short, medium and long horizons.
- Material physical risks: acute (flood, wildfire, storm) and chronic (sea-level, heat)
- Material transition risks: policy, technology, market, reputation
- Effects on financial position, performance and cash flows
- Climate resilience of the strategy, assessed through scenario analysis, including the adaptation measures relied on
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Chapter 3: Risk Management
Inside the risk register, not beside it.
Disclose the processes used to identify, assess, prioritise and monitor climate-related risks, and how those processes are integrated into the entity's overall risk management. For FRFIs, B-15 makes this part of the Risk Appetite Framework.
- Documented identification and assessment processes for climate risks
- Prioritisation logic, including materiality thresholds
- Integration with enterprise risk management and internal control frameworks
- For FRFIs: explicit linkage to ICAAP, ORSA and capital planning
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Chapter 4: Metrics & Targets
The metric that needs a map.
Disclose Scope 1 and Scope 2 GHG emissions (gross, in tCO2e), the cross-industry metric categories, any industry-specific metrics, and the targets used to manage risks and opportunities. Under B-15, the cross-industry metrics phase in a year behind the rest: FY2025 for D-SIBs and IAIGs, FY2026 for smaller banks and other insurers.
- The amount and percentage of assets or business activities vulnerable to physical climate risk, which cannot be produced without knowing where those assets are
- Capital deployed toward climate-related risks and opportunities, including adaptation
- Scope 1 and Scope 2 GHG emissions, calculated under the GHG Protocol
- Industry-based metrics from the SASB-aligned guidance, plus targets with units, base year, milestones and progress
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Chapter 5: Scope 3 GHG
The part that keeps moving.
CSDS 2 covers Scope 3 across the 15 GHG Protocol categories, with a 3-year Canadian runway that puts it at FY2028. B-15 mirrors that for FRFIs, and in January 2026 OSFI deferred the off-balance-sheet AUM piece to a future date rather than the FY2029 previously signalled.
- All 15 Scope 3 categories, with a justified materiality assessment
- Category 15 (Investments / Financed Emissions) for banks, insurers, asset managers
- For FRFIs: the off-balance-sheet AUM expectation deferred to a future date, January 2026
- The ISSB issued targeted amendments to IFRS S2 on GHG disclosure in December 2025, effective for periods beginning on or after 1 January 2027, which the CSSB has consulted on importing into CSDS 2
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Chapter 6: Scenario Analysis
Resilience, evidenced.
CSDS 2 calls for climate scenario analysis to test the resilience of strategy and business model, with the quantitative side carrying a 3-year Canadian runway to FY2028. OSFI B-15 also requires scenario analysis, plus participation in the standardised exercises OSFI sets.
- Multiple pathways: low-warming and high-warming, including 1.5°C-aligned
- Time horizons aligned to the entity's strategic planning cycles
- For FRFIs: participation in OSFI's Standardised Climate Scenario Exercises
- Asset-level inputs over postal or sector averages, and a resilience conclusion the scenarios actually support
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Chapter 7: OSFI B-15
Where the mandate already lives.
Guideline B-15 governs climate risk management and disclosure for FRFIs. The current version dates from 7 March 2025, aligned to the final CSDS standards, and was amended in January 2026. The largest banks and insurance groups started at FY2024; everyone else joined a year later, with the cross-industry metrics a year behind that again.
- Annexes 2-1 and 2-2 mirror IFRS S2 and CSDS 2 disclosure
- Governance, strategy and risk management: FY2024 for D-SIBs and IAIGs, FY2025 for other FRFIs
- Cross-industry metrics: FY2025 for D-SIBs and IAIGs, FY2026 for smaller banks and other insurers
- Scope 3 at FY2028, with the off-balance-sheet AUM component deferred to a future date in January 2026
- Climate Risk Returns: standardised submission 180 days after fiscal year-end, from mid-2025 for D-SIBs and IAIGs and mid-2026 for the rest
CSDS-grade data is asset-level data.
CSDS 2 and OSFI B-15 both ask the same question: how is climate actually flowing through the balance sheet? Postal-code averages won't survive contact with the Annexes, and they cannot produce the one metric that asks how much of your book sits in harm's way.
Asset-level physical risk
Address, parcel and asset granularity. Not FSA averages, not provincial summaries. Flood, wildfire, severe wind, heat and coastal exposure, per asset, with documented lineage.
Forward-looking, multi-pathway
2030, 2050 and 2100 horizons under at least two pathways: a low-warming scenario plus a higher-warming case. Historical losses cannot answer a forward-looking standard, and Canadian catastrophe records are a poor guide to Canadian catastrophe futures.
Resilience you can evidence
CSDS 2 asks for a resilience conclusion, not a hazard map. Where defences, retrofits or siting decisions reduce the exposure you book, the measure and its effect belong in the assessment, alongside the capital you have deployed toward adaptation.
One dataset, many disclosures
CSDS follows IFRS S1 and S2, both built on TCFD. The same physical risk dataset feeds B-15 returns, ISSB filings, CSRD reports for Canadian subsidiaries in Europe, and SEC filings for cross-listed issuers.
Climate Risk Returns: standardised
OSFI's Climate Risk Returns collect physical risk exposure by asset class and geography, credit metrics including probability of default and loss given default, and insurance figures such as probable maximum losses. Filing runs 180 days after fiscal year-end, from mid-2025 for the largest institutions and mid-2026 for the rest. Methodology has to be defensible under supervisory review, not just plausible.
Vulnerable assets, as a percentage
The cross-industry metrics ask for the amount and percentage of assets or business activities vulnerable to physical climate risk. A percentage is a ratio of two numbers you have to be able to defend: what is exposed, and against what denominator.
Physical climate risk data, built for CSDS and OSFI B-15.
Spectra is the physical climate risk data platform behind CSDS and OSFI B-15 disclosures at banks, insurers and asset managers with over $13.5 trillion in combined AUM. Asset-level exposure across Canadian and global portfolios, multi-pathway scenarios, adaptation costed asset by asset, and methodology built to survive supervisory review.
Asset-level exposure, 2bn+ assets
Material physical climate risk for every asset in scope. 12 hazards, building-level vulnerability, geolocation precision down to address and parcel. The granularity OSFI B-15 Annexes 2-1 and 2-2 expect, without FSA averages.
Multi-pathway scenarios CSDS 2 expects
CMIP6 SSPs and CMIP5 RCPs covering low-warming and high-warming pathways including 1.5°C-aligned, plus NGFS pathways for the financial-sector view. 2030, 2050 and 2100 horizons, ready for OSFI's Standardised Climate Scenario Exercises and the FY2028 quantitative cliff.
Hazard exposure to dollars
Annual losses in monetary value and percentage, business disruption risk and confidence intervals, plus the vulnerable-asset amounts and percentages the cross-industry metrics ask for. The translation from physical hazard to financial impact that CSDS 2 strategy disclosures and B-15 returns both demand.
Adaptation, costed and evidenced
A resilience statement is only as good as the measures behind it. Adapt quantifies defence and retrofit options asset by asset, with capex, avoided loss and payback, so the resilience conclusion in your CSDS 2 strategy disclosure and the capital-deployment metric rest on something documented.
Climate Risk Returns ready
Model risk management aligned, ISO 27001 and ISO 14001 certified, full methodology documentation. Defensible under OSFI supervisory review for Climate Risk Returns submission, and ready to feed parallel ISSB, CSRD and SEC filings from the same data spine.
Canadian coverage, global comparability
Flood, wildfire, severe wind, heat, cold and coastal exposure across Canadian property, infrastructure and commercial portfolios, scored on the same methodology as the rest of a global book, so a Canadian subsidiary and its parent are not arguing about whose numbers are right.
Are you ready for CSDS and OSFI B-15 climate disclosure?
Seven questions across the disclosures where physical risk actually bites. Not audit-grade. A useful gut-check before the next reporting cycle, the next investor meeting, or the next OSFI return.
CSDS readiness self-check
CSDS and OSFI B-15: the questions Canadian disclosure leads actually ask.
What is CSDS?
CSDS stands for the Canadian Sustainability Disclosure Standards: CSDS 1 (general sustainability) and CSDS 2 (climate-related disclosure). Issued by the Canadian Sustainability Standards Board (CSSB) on 18 December 2024 and effective for annual reporting periods beginning on or after 1 January 2025. CSDS adopts the global ISSB baseline (IFRS S1 and S2) with Canadian transition reliefs, including a 3-year deferral on Scope 3 GHG emissions and on the quantitative side of scenario analysis.
Who has to comply with CSDS in Canada?
CSDS itself remains voluntary. The Canadian Securities Administrators (CSA) paused the proposed mandatory rule (NI 51-107) on 23 April 2025, citing global regulatory uncertainty, and has not announced a restart since. That does not make climate disclosure optional: existing securities law still requires material risks to be disclosed, ten of Canada's largest pension and asset managers representing more than C$2.25 trillion in AUM endorsed CSDS when it was issued, and for federally regulated financial institutions (around 350 banks, insurers and trust companies) CSDS-aligned disclosure is already mandatory under OSFI Guideline B-15.
What is OSFI Guideline B-15, and what is due when?
OSFI Guideline B-15 (Climate Risk Management) is the Office of the Superintendent of Financial Institutions' mandatory climate risk and disclosure expectation for federally regulated financial institutions (FRFIs). The current version dates from 7 March 2025, aligned to the final CSSB standards, and was amended in January 2026. Governance, strategy and risk management disclosures applied from FY2024 for D-SIBs and IAIGs and FY2025 for other FRFIs. The cross-industry metrics sit a year behind: FY2025 for D-SIBs and IAIGs, FY2026 for smaller banks and other insurers. Scope 3 sits at FY2028. Foreign bank branches are excluded from B-15.
What changed for Canadian climate disclosure in 2026?
On 8 January 2026, as part of a regulatory-efficiency push, OSFI deferred the disclosure expectation for financed emissions related to off-balance-sheet assets under management, along with the consultation attached to it, to a future date, and announced it would wind down its Climate Risk Forum. Read carefully, the relief is narrow: it lands on an emissions number that was already the hardest to compute. The guideline stands, the disclosure timetable for governance, strategy, risk management and metrics stands, the scenario analysis expectation stands, and the Climate Risk Returns still ask FRFIs where their exposed assets are. Separately, the ISSB issued targeted amendments to IFRS S2 on GHG disclosures in December 2025, effective for periods beginning on or after 1 January 2027, and the CSSB has consulted during 2026 on bringing the equivalent amendments into CSDS 2.
What's the difference between CSDS 1 and CSDS 2?
CSDS 1 sets the general requirements for disclosing sustainability-related financial information across any topic, mirroring IFRS S1. CSDS 2 covers climate specifically, with disclosures across the four TCFD pillars (Governance, Strategy, Risk Management, Metrics & Targets), Scope 1 and Scope 2 GHG emissions in tCO2e, scenario analysis and a climate resilience conclusion, the cross-industry metrics including the amount and percentage of assets vulnerable to physical climate risk, and Scope 3 across the 15 GHG Protocol categories. CSDS 2 mirrors IFRS S2. Most Canadian reporters focus on CSDS 2 first.
When does CSDS Scope 3 reporting start?
Scope 3 GHG emissions disclosure under CSDS 2 is deferred to annual reporting periods beginning on or after 1 January 2028, a 3-year transition relief from the underlying ISSB timeline, and OSFI B-15 mirrors that FY2028 date for FRFIs. The off-balance-sheet AUM component of FRFI Scope 3 was originally signalled for FY2029; in January 2026 OSFI deferred that expectation to a future date it has not yet named, so FY2029 should no longer be treated as the planning assumption. Scope 3 timing has moved more than once, which is a reason to build the parts of the disclosure that have not moved.
Does CSDS 2 expect anything on adaptation and resilience?
Yes, and it is the part of the standard closest to the physical world. CSDS 2 asks for an assessment of the climate resilience of the strategy and business model, informed by scenario analysis, rather than a hazard inventory. The cross-industry metrics then ask for the amount and percentage of assets or business activities vulnerable to physical climate risk, and for the capital deployed toward climate-related risks and opportunities, which includes adaptation spending. Where a defence, retrofit or siting decision is the reason an exposure is lower, that measure sits inside the assessment and needs the same evidence trail as any other input. Adapt is built for that step.
How does Climate X help with CSDS and OSFI B-15?
Climate X provides asset-level physical climate risk data built for CSDS 2 strategy and metrics disclosures, OSFI B-15 Annexes 2-1 and 2-2, and the standardised Climate Risk Returns. The Spectra platform covers 2 billion+ assets globally across 12 hazards, with multi-pathway scenarios using CMIP6 SSPs, CMIP5 RCPs and NGFS pathways across 2030, 2050 and 2100 horizons, and translation of hazard exposure into expected loss in dollars. Adapt costs the response asset by asset, so a resilience conclusion rests on measures you can evidence. Methodology is ISO 27001 and ISO 14001 certified and defensible under OSFI supervisory review. Explore Spectra or talk to a climate risk expert about your CSDS roadmap.
Voluntary in name.
Already being asked for.
