As the regulatory landscape evolves in step with rapid technological change, federally regulated financial institutions (FRFIs) face a pressing question: how can they build a foundation today that will support compliance with increasingly sophisticated regulatory requirements tomorrow?
The Office of the Superintendent of Financial Institutions’ (OSFI) Guideline B-13: Technology and Cyber Risk Management marks a milestone in this journey. As FRFIs navigate a landscape of emerging risks, digital transformation, and heightened expectations around governance and accountability, B-13 signals a broader shift toward proactive risk management—one that can be strategically managed and optimized with automation and AI.
In this article, we explore OSFI’s Guideline B-13, the risks of non-compliance, how it compares with other frameworks, and our view of how technology can transform financial services compliance.
OSFI risk management guidelines for FRFIs
Effective Jan. 1, 2024, OSFI's Guideline B-13 is a foundational framework for financial institutions navigating digital risk. It sets clear expectations for FRFIs to enhance their digital practices in line with evolving risks across three broad categories of requirements:
Guideline B-13 is part of OSFI’s four inter-related risk management guidelines for financial institutions. Collectively, they all set the expectation that FRFIs will create and implement risk-based frameworks.
Achieving compliance with B-13 today can significantly reduce the cost and effort required to comply with E-23 or other regulations in the future.
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Read moreThe risks of non-compliance with OSFI B-13
With regulations changing at breakneck speed, financial institutions that don’t prioritize effective, efficient compliance today risk falling dangerously behind—and the cost of catching up later will be far higher.
Failing to meet B-13 expectations doesn’t just invite regulatory consequences—it exposes institutions to a range of risks.
FRFIs can face regulatory penalties, increased scrutiny from OSFI, and board oversight weaknesses, in addition to reputational damage from customers, partners, and the public.
Gaps in service experience, increasing IT and data expenses, and increased likelihood of operational disruption could plague organizations if they don’t meet compliance regulations. They could also face potential financial losses.
Organizations risk a heightened susceptibility to cyber attacks and data breaches if they fail to act on compliance efforts now, as well as higher costs and manual efforts to manage security and cyber resilience.
OSFI B-13 vs. NIST CSF 2.0: How they compare
FRFIs that have already voluntarily aligned their cybersecurity practices with the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) 2.0 are generally starting from a solid foundation of risk-based practices However, B-13 introduces more prescriptive expectations tailored specifically to the Canadian financial sector, raising the bar for compliance.
Relying solely on NIST may leave critical compliance gaps, especially in areas where OSFI demands more specificity, documentation, and board-level oversight.
| OSFI B-13 domain | Level of overlap between OSFI B-13 and NIST CSF 2.0 |
|---|---|
| Governance and risk management | |
| Accountability and organizational structure |
|
| Technology and cyber strategy |
|
| Technology and cyber risk management framework |
|
| Technology operations and resilience | |
| Technology architecture |
|
| Technology asset management |
|
| Technology project management |
|
| System development life cycle |
|
| Change and release management |
|
| Patch management |
|
| Incident and problem management |
|
| Technology service measurement and monitoring |
|
| Disaster recovery |
|
| Cybersecurity | |
| Identify |
|
| Defend |
|
| Detect |
|
| Respond, recover, and learn |
|
While NIST provides a widely used global benchmark for managing cyber risk, B-13 is specifically tailored to Canadian FRFIs.
Why technology is the key to faster, smarter, and leaner compliance
Financial services institutions face staggering complexity—dozens of regulations applied across hundreds of scenarios and systems, each with thousands of capabilities.
Technology-driven compliance—specifically, tools like generative AI and agentic AI—are a strategic lever for risk transparency, operational agility, and meeting regulatory standards like OSFI B-13 and future regulations that arise. Agentic AI is a new class of AI that builds on GenAI’s creative ability but drives towards independent execution, goal setting, and adaptation.
We've streamlined the intricate compliance landscape for financial institutions into
four AI-powered areas that will help you overcome complexity:
Plan policy enablement
Codify policy implementation
Apply policy infrastructure
Monitor and report
Plan policy enablement
Tackling the growing complexity and sophistication of multi-jurisdictional compliance facing FRFIs requires a strategic approach to understanding and planning for regulatory adoption. Disparate systems for monitoring and managing compliance—often siloed across cloud computing platforms and traditional on-premises infrastructure—create inefficiencies and blind spots for financial institutions. This fragmentation makes it difficult to get a holistic view of an organization’s compliance posture.
Leading institutions are making targeted investments in four core areas:
- Proactive compliance automation to reduce lag in regulatory updates.
- AI-enabled documentation and surveillance to meet evolving disclosure requirements.
- Cloud-native infrastructure modernization to enable scalable support for multi-jurisdictional reporting.
- Centralized data governance to meet cross-border data lineage, consent and audit trail obligations.
Codify policy implementation
By codifying policies and compliance rules into automated, machine-readable formats, FRFIs can reduce human hours and errors, and streamline repeatable processes. This approach can alleviate costs, enhance auditability, and ensure real-time monitoring, embedding compliance seamlessly into an organization’s development and operations.
What is Policy as Code?
Policy as Code is the practice of codifying regulations and policies across the organization to build repeatable, reportable controls. FRFIs can apply Policy as Code to their regulations to enforceable, reportable controls across the organization.
What is Compliance as Code?
For example, Policy-as-Code bots can help financial institutions translate regulatory policies into actionable insights and codified controls. From there, Compliance as Code can operationalize those codified rules into continuous, automated compliance enforcement and monitoring.
For example, Policy-as-Code bots can help financial institutions translate regulatory policies into actionable insights and codified controls. From there, Compliance as Code can operationalize those codified rules into continuous, automated compliance enforcement and monitoring.
Apply policy infrastructure
Leveraging Infrastructure as Code aligns application and infrastructure updates under a single source of truth. Institutions can then apply a codified control set to their technology infrastructure, minimizing the risk of errors.
What is Infrastructure as Code?
Infrastructure as Code is a method of managing and provisioning infrastructure across private/public clouds, building automation, and maintaining configuration through code, building automation and maintaining configuration.
Infrastructure as Code offers improved visibility into infrastructure deployment, facilitating code reuse and enabling rapid, tool-supported infrastructure updates. Shifting to a cloud-based compliance framework also helps lower accumulating legacy debt of on-premise software.
Monitor and report
As regulatory expectations grow more complex, there’s an increasing need to unify disparate data sources to enable regular reviews and continuous compliance monitoring. Agentic AI models are a powerful tool that can facilitate regular compliance reviews, bring attention to problematic areas, and generate alerts for continuous monitoring.
Implementing a centralized regulatory monitoring and reporting solution, like our ComplyHub solution, can break down these silos, provide real-time data access and tailored insights, and curate application-based compliance reports.
Regardless of where you are in your digital adoption journey, there are practical AI-driven tools and efficiencies you can begin leveraging today. From automating routine compliance tasks to enhancing risk detection, even incremental steps can lead to significant gains across your compliance operations.
How BDO’s ComplyHub transforms compliance in financial services
Our ComplyHub solution is a cloud-based interactive compliance platform that centralizes and automates end-to-end compliance management processes for your organization. It’s a scalable, all-in-one compliance solution tailored to the financial services industry that evolves as your organization and the compliance landscape do. ComplyHub integrates seamlessly with your data sources to analyze data in real time and transform it into visual insights, helping you understand your compliance posture across applications to proactively mitigate security risks.