Sustainable Transformation of the Colombian Financial System: New Regulations on Comprehensive Environmental, Social, and Climate Risk Management

External Circular 015 of 2025, issued on October 3 by the Colombian Financial Superintendency, marks a milestone in the evolution of the national financial system towards sustainability. This mandatory regulation for supervised entities (with specific exceptions) establishes a robust legal framework for integrating environmental, social, and climate risks (ESCR) into financial management systems.

What changes with this Circular?

• New Chapter XXXIII in the Basic Accounting and Financial Circular (CBCF).
• Amendments to sections 3.1.4 and 3.2 of Chapter IV of the Basic Legal Circular (CBJ).
• Obligation to incorporate ESCR risks into internal policies, credit operations, investments, and insurance.
• Training plans, periodic reports, and technical documentation on risk categorization and monitoring.

Types of Risks Identified

• Physical risks: Extreme weather events (hurricanes, droughts, floods).
• Transition risks: Regulatory, technological, and economic changes toward a low-carbon economy.

Voluntary Reference Indicators (Annex 1)

Although not mandatory, these indicators allow vulnerabilities to be measured and strategic decisions to be guided:

• IERF: Physical Risk Exposure Index
• IRTE: Energy Transition Risk Index
• IERS: Social Risk Exposure Index
• PFCI / IFCC: Participation in International Climate Finance Programs and Blended Climate Finance

Implementation Deadlines

• Action plan: Within the first 6 months.
• Full implementation: Maximum 18 months.
• Early application: Permitted and publicly recognized by the Superintendency.

Why is this regulation key?

Ignoring these guidelines may expose entities to reputational, financial, and operational risks. On the other hand, compliance:

• Strengthens institutional trust.
• Protects vulnerable communities.
• Positions Colombia as a regional leader in sustainable finance.

Is your institution prepared?

Now is the time to review policies, train teams, and design strategies aligned with the new regulations. If you need specialized legal advice to implement this regulation, our team is ready to assist you.

info@pmabogados.co