Canada's Office of the Superintendent of Financial Institutions updates Climate Risk Returns after first reporting cycle

Canada's Office of the Superintendent of Financial Institutions (OSFI) published a lessons learned report on the first submission cycle of its Climate Risk Returns and released updated reporting forms, including amendments effective in fall 2025 intended to reduce reporting burden and improve data quality. The initial filings came from Canada’s six systemically important banks and four internationally active insurance groups. OSFI identified challenges such as data gaps, reliance on proxies, and inconsistent reporting practices, while noting the returns captured new physical risk data not previously collected through other regulatory returns. The fall 2025 amendments remove certain requirements to focus on material exposures, refine industry classifications to focus on high-emitting sectors, clarify definitions to improve consistency, and recommend supplemental notes and a project plan to support more accurate assessment of submissions. Smaller and medium-sized institutions are preparing to file their first returns in 2026.