OSFI Guideline E-23: Model Risk Management Deadline May 2027

OSFI Guideline E-23: Model Risk Management Deadline May 2027** OSFI's final Guideline E-23 takes effect May 1, 2027, expanding model risk management requirements to all AI/ML models across federally regulated financial institutions. **Evidence:** - Final guideline released September 2025, effective May 1, 2027 - Expands applicability to insurers (previously banks only) - Requires "enterprise-wide model risk management" using risk-based approach - Legal analysis: "Addresses emerging technology risks and imposes risk management requirements on the increased model usage by FRFIs" **Strategic Recommendation:** - Q1 2026: Establish enterprise-wide model inventory - Q1-Q2 2026: Implement continuous monitoring infrastructure - Investment: $10-30M for mid-market compliance *** ## Tier-2 Signals (Strong Signals)