Unadhi · Canada

OSFI E-23: building your AI model inventory before 1 May 2027

OSFI published the final Guideline E-23, Model Risk Management, on 11 September 2025. It takes effect on 1 May 2027 for banks, foreign bank branches, insurers and trust & loan companies (OSFI). Pension plans were taken out of scope (OSFI letter). It is supervisory guidance, not a statute, and it applies in proportion to an institution's size and risk.

A starter inventory record (our suggestion, not OSFI's form)

• Model ID, name, version
• Type: statistical, AI/ML, generative AI, or vendor/third-party
• Business owner and developer
• Use: which decisions it supports
• Risk rating, with the criteria you used
• Data sources, and whether they include personal information
• Last validation, next review, known limitations
• Monitoring metrics and drift thresholds
• Approval and change history; decommission date

Credit unions and provincial institutions

E-23 binds only federally regulated institutions. Provincially regulated credit unions answer to their provincial regulator, but many use E-23 as a benchmark. Check with yours.

Free example

Ask for a free example entry for one of your models. We fill it in from what you tell us, and you keep it.

Free first: the Unadhi Register keeps 1 AI system free: https://unadhi.com/register/ · Paid, only if useful: membership $19/month or $190/year; checkout: https://mininglife1.gumroad.com/l/euro-ai-register. Not legal advice. Checked against official sources on 13 Oct 2026. Please tell us if something has changed.