Physical climate risk data,
ready for CSDS and OSFI B-15.
The standard is here. The mandate is paused. The pressure isn't. The Canadian Sustainability Disclosure Standards (CSDS 1 and CSDS 2) follow the global ISSB baseline. Voluntary for public issuers. Mandatory in practice for the banks and insurers under OSFI Guideline B-15.
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). Mandatory in practice for federally regulated financial institutions under OSFI Guideline B-15.
Voluntary for all Canadian public issuers, but already endorsed by Canadian institutional investors with $2.25tr+ in AUM. Mandatory under OSFI B-15 for ~350 federally regulated banks, insurers and trust companies (excluding foreign branches): D-SIBs and IAIGs from FY 2024, other FRFIs from FY 2025. Scope 3 deferred to FY 2028 (off-balance-sheet AUM: FY 2029).
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. Already in effect.
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. Investor pressure didn't either.
Mandatory for the financial sector.
Around 350 federally regulated banks, insurers and trust companies are already inside the B-15 reporting cycle. The guideline now mirrors CSDS.
$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. Investor scrutiny doesn't wait for a CSA rule.
The CSA will revisit. Plan now.
The CSA expects to revisit the mandatory rule in future years. Catching up to ISSB-aligned disclosure once it returns is much harder than building the data foundation now.
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.
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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 strategy, supported by scenario analysis
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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
Numbers that tie back to the strategy.
Disclose Scope 1 and Scope 2 GHG emissions (gross, in tCO2e), the cross-industry metric categories from CSDS 2, any industry-specific metrics, and the targets used to manage risks and opportunities, including progress toward each.
- Scope 1 and Scope 2 GHG emissions, calculated under the GHG Protocol
- Cross-industry metrics: transition risk, physical risk, climate-related opportunities, capital deployment, internal carbon prices, remuneration
- Industry-based metrics from the SASB-aligned guidance
- Quantitative targets, units, base year, milestones and progress
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Chapter 5: Scope 3 GHG
The hardest number on the page.
CSDS 2 covers Scope 3 across the 15 GHG Protocol categories. Voluntary adopters get a 3-year runway, deferring Scope 3 to FY 2028. OSFI B-15 mirrors this for FRFIs.
- All 15 Scope 3 categories, with a justified materiality assessment
- Category 15 (Investments / Financed Emissions) for banks, insurers, asset managers
- For FRFIs: off-balance-sheet AUM Scope 3 deferred to fiscal year-end 2029
- Methodology, data quality, estimates and limitations all disclosed
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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. The quantitative side gets a 3-year runway, deferring to FY 2028 for voluntary adopters. OSFI B-15 also requires scenario analysis, plus participation in standardised exercises set by OSFI.
- 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 postcode or sector averages
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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. Updated to match the final CSDS standards. The largest banks and insurance groups are already inside the cycle; smaller FRFIs joined a year later.
- Annexes 2-1 and 2-2 mirror IFRS S2 and CSDS 2 disclosure
- Scope 3 GHG: deferred to FY 2028 (off-balance-sheet AUM: FY 2029)
- Mandatory Climate Risk Returns: standardised data submission to OSFI
- Penalties for non-compliance flow through OSFI's prudential supervision toolkit
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? Postcode averages won't survive contact with the Annexes.
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.
Scope 3 / financed emissions
The 2028 deferral buys runway, not a pass. Banks need PCAF-grade methodology (Partnership for Carbon Accounting Financials) across loan books and investments. Asset-level inputs make Category 15 defensible.
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 require FRFIs to submit standardised emissions and exposure data. Methodology has to be defensible under supervisory review, not just plausible.
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 trillion in combined AUM. Asset-level exposure across Canadian and global portfolios, multi-pathway scenarios, audit-ready methodology, all in one place.
Asset-level exposure, 1.5bn assets
Material physical climate risk for every asset in scope. 11 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. 2030, 2050 and 2100 horizons. Ready for OSFI's Standardised Climate Scenario Exercises and the FY 2028 quantitative cliff.
Hazard exposure to dollars
Annual losses in monetary value and percentage, business disruption risk and confidence intervals. The translation from physical hazard to financial impact that CSDS 2 strategy disclosures and B-15 returns both demand.
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.
Are you ready for CSDS and OSFI B-15 climate disclosure?
Seven questions, one per chapter. Not audit-grade. A useful gut-check before the next disclosure 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?
For now, CSDS itself is voluntary. The Canadian Securities Administrators (CSA) paused the proposed mandatory rule (NI 51-107) on 23 April 2025, citing global regulatory uncertainty in the U.S. and EU. However, ten of Canada's largest pension and asset managers, representing more than $2.25 trillion in AUM, publicly endorsed CSDS. 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?
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 most recent update, on 7 March 2025, aligned B-15 with the final CSSB standards. The largest banks and insurers (D-SIBs and IAIGs) were the first wave for fiscal year-end 2024; other FRFIs joined for fiscal year-end 2025. Foreign bank branches are excluded from B-15.
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 Scope 3 across the 15 GHG Protocol categories. CSDS 2 mirrors IFRS S2. Most Canadian voluntary adopters in the first reporting cycles will focus on CSDS 2.
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. OSFI B-15 mirrors this for FRFIs: Scope 3 disclosure is now expected for fiscal year 2028. There is an additional one-year deferral (fiscal year 2029) for the off-balance-sheet AUM component of FRFI Scope 3, recognising the methodology and data challenges in measuring financed emissions on assets under management.
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 1.5 billion assets globally with 11 hazards, multi-pathway scenarios using CMIP6 SSPs and CMIP5 RCPs across 2030, 2050 and 2100 horizons, and translation of hazard exposure into expected loss in dollars. 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 today.
Defensible tomorrow.
