风向变迁：2025-2026年加拿大可持续金融市场回顾与展望报告

2025 REVIEW – 2026 OUTLOOK MARCH 2026 1. INTRODUCTION paused further work on proposed mandatoryclimate-disclosure rules, citing a rapidly evolvingglobal economic and geopolitical landscapeand competitiveness considerations.5Thesedevelopments highlight a landscape in whichpolicy and regulatory frameworks are beingreviewed and adapted in response to evolvingmarket and informational needs. 2025 marked continued evolution in Canada’ssustainable finance policy and regulatorylandscape. In its Fall Budget 2025, thefederal government announced its intentionto propose legislative amendments to theCompetition Act’s greenwashing provisions,including removing the requirementthat environmental business claims besubstantiated using internationally recognizedmethodology and eliminating direct third-partyaccess to the Competition Tribunal for suchclaims.1The government indicated that theproposed amendments are intended to providegreater certainty to the marketplace whilemaintaining protections against false claims.2Regulators also refined ongoing climate-related work. OSFI amended its approachto climate-risk oversight through updates toGuideline B-15 in 2025, providing additionaldirection for federally regulated financialinstitutions on governance, risk management,and disclosure expectations,3,4reaffirmingexpectations for the integration of physical andtransition climate risks, and signaling alignmentwith final Canadian Sustainability StandardsBoard (CSSB) climate disclosure standards.The Canadian Securities Administrators (CSA) At the same time, the federal governmentcontinued to leverage sustainable financeinstruments to support public investmentpriorities. In 2025, Canada completed twogreen bond transactions totaling CAD 4.5billion, including its first-ever 30-year greenbond issuance, both of which saw stronginvestor interest.6,7These transactions pointto sustained demand for climate-alignedsovereign instruments and reinforce theongoing relevance of sustainable financewithin Canada’s fiscal toolkit. The governmenthas continued its sovereign labelled debtprogram into 2026 with the issuance of a new10-year green bond.8 Additional signals – including shifts in policylanguage toward adaptation, resilience, andenergy security – continued to shape howmarket participants assess climate-relatedrisks and opportunities. 2. IMPLICATIONS FOR THEFINANCIAL SECTOR 2.2 For Insurers For insurers, federal policy developments in2025 – particularly the evolution of industrialcarbon pricing, clean-economy incentives, andemerging sustainable investment guidelines- shape the operating environment forunderwriting climate-exposed assets. Clearerfederal signals regarding transition pathways,infrastructure investment, and resiliencepriorities influence insurers’ assessments offuture loss patterns, asset-level transitionrisk, and geographic exposure, all of whichfeed directly into underwriting capacity,pricing, and reinsurance strategies. At thesame time, OSFI’s continued focus on climate-risk governance reinforces expectationsthat insurers incorporate both physicaland transition risk factors into capital andreserving decisions. 2.1 For Risk & Compliance Teams For risk and compliance teams, 2025developments underscore the need to operatewithin a divergent regulatory environment,where OSFI continues to advance climate-risk expectations while the CSA has pausedmandatory climate-disclosure rulemaking.This divergence requires teams to reconcileprudential expectations—governance, datacontrols, risk quantification, and scenarioanalysis—with a securities landscapewhere issuer-level disclosures remainless standardized. As a result, institutionsmust strengthen internal climate-risk dataframeworks and ensure consistency acrossregulatory filings, internal models, and board-level reporting. These dynamics have long-term implicationsfor adaptation finance, where insurers playa critical role in signaling where risk isbecoming uninsurable and where resilienceinvestments may reduce loss severity. Asgovernments expand discussions of resilientinfrastructure and adaptation funding,insurers will increasingly need to evaluatehow federal policy and market incentivescan support improved climate-risk mitigationacross their portfolios. At the same time, climate scenario testingand strategic preparedness are becomingcentral to enterprise-risk management. Globalexamples – such as JPMorgan’s 2024–2025analysis of a Category-5 hurricane directlystriking major U.S. financial hubs and itsimplications for liquidity, credit losses, andoperational continuity – illustrate how extremebut plausible climate shocks can stressfinancial institutions. Scenario exercises thatincorporate acute physical events, transition-policy shifts, or supply-chain disruptions willbe increasingly important for capital planning,contingency strategies, and demonstratingsupervisory readiness. 2.3 For Lenders 2.4 For Institutional Investors For lenders, the 2025 policy and regulatorydevelopmen