Colombia strengthens environmental, social, and climate risk management in the financial sector: External Circular 015 of 2025 from the Financial Superintendence

In brief

On 3 October 2025, the Financial Superintendence of Colombia issued External Circular 015 of 2025 (“Circular”), setting forth new instructions for the management of environmental and social risks, including climate-related risks, for all supervised entities. This responds to the growing importance of these risks for the resilience and sustainability of Colombia’s financial system.


Contents

Key takeaways

  • Scope: The Circular requires supervised entities to implement mechanisms, tools, and procedures to identify, measure, control, and monitor environmental and social risks, including climate risks, across all operations.
  • Regulatory integration: Chapter XXXIII is added to the Basic Accounting and Financial Circular (CBCF), integrating these risk management requirements into the existing regulatory framework.
  • Internal control updates: Policies and processes for risk management in the Basic Legal Circular are updated.
  • Deadlines: Entities have up to 18 months to implement the provisions and must submit an implementation plan within the first six months.
  • Early adoption: Early implementation is allowed, with public recognition for entities that do so.
  • Entry into force: The Circular is effective upon publication.

Additional information

Please do not hesitate to contact us in case you have any questions or require our advice.

Click here to read the Spanish version.


Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.