Sustainability and management of ESG risks?

Sustainability and ESG will accompany us in the coming years!

Climate change is increasingly becoming a focus of supervision and requires integration of climate and environmental- and ESG risks into risk management

European Central Bank
“Institutions are expected to properly document their assessments of climate-related and environmental risks in terms of their business environment [...] ECB expects institutions to consider climate-related and environmental risks – as drivers of existing categories of risk – when formulating and implementing their business strategy and governance and risk management frameworks. It further explains how the ECB expects institutions to become more transparent by enhancing their climate-related and environmental disclosures.”

European Banking Authority
“ESG risks to institutions are defined as risks that stem from the current or prospective impacts of ESG factors on their counterparties or invested assets, i.e. the risks arising from the core activities of institutions. ESG risks materialise through the traditional categories of financial risks (credit risk, market risk, operational and reputational risks, liquidity and funding risks) [...] The EBA sees a need to enhance, in a risk-based and proportionate manner, the incorporation of ESG risks into institutions’ business strategies, internal governance arrangements and risk management frameworks.”

European Systemic Risk Board
“To quantify the significance of these risks, policymakers could seek enhanced disclosure of the carbon intensity of non-financial firms. The associated burdens on financial firms could then be stress tested under the negative scenario of a late and sudden transition.”

Sustainability encompasses the three pillars Environmental (E), Social (S), and Governance (G)

Environment (E)

Climate risks: Physical

  • Actue risks 
    • Heat
    • Flood
    • Hurricanes
    • Wildfires
    • etc. 
  • Chronic risks 
    • Temperature rise
    • Precipitation
    • Agricultural productivity
    • Sea level rise
    • etc.

Climate risks: Transition

  • Technological changes
  • Political, regulatory and legal changes
  • Changing market sentiment and stakeholders
  • Reputational and legal risks
  • etc.

Other risks

  • Bio-diversity
  • Water quality
  • Waste
  • etc.

Social (S)

Risks

  • Working conditions
  • Diversity
  • Social commitment
  • etc.

Governance (G)

Risks

  • Anti-corruption
  • Compliance
  • Data protection
  • etc.

EU banks are under pressure due to increased supervisory expectations and regulatory requirements for ESG risks

Regulatory requirements

Regulators have published a long list of expectations and regulatory requirements regarding the incorporation of ESG risks in credit and risk processes. Inspections and assessments have already been carried out in 2021 and are in process in 2022 by ECB (e.g. ECB Thematic Review of C&E, Climate stress test)

Disclosure and reporting

Apart from implementation of ESG regulatory requirements, banks are preparing Non-financial reporting and disclosures considering a large number of regulatory documents and current as well as future ESG reporting Standards (EU Taxonomy, CSR-RUG (2022) and CSRD (2023), CRR disclosures, Standards: GRI, SASB, TFCFD and new EFRAG)

Global initiatives

A number of global ESG and climate initiatives our growing as well as their participation rate. External pressure is increasing as well as commitments and expectations

What needs to be done?

The requirements relate to the following main areas of implementation

The regulator expects that climate and environmental risks will play a central role in the definition of strategies and business plans as well as the risk appetite of the supervised companies. Sustainability risks must be systematically analyzed as part of the risk inventory and taken into account in the risk-bearing capacity calculation. One particular expectation of the supervisory authority is that risk scenarios are also integrated into the capital planning processes - taking into account medium- and longer-term developments. With an increased stakeholder and regulatory focus on climate risk management and the disclosures banks look to integrate the following aspects within their Group Risk Management Framework:

  • Development of a sustainability strategy or expansion of the business strategy and derivation of a consistent risk strategy
  • Clear division of responsibilities (“3 lines of defence” approach in the ECB Guide),
  • Targeted development of expertise, if necessary, supported by a sustainability officer
  • Anchoring sustainability in the internal governance system
3
  • Structured risk driver analysis and translation of E(SG) factors into existing risk types.
  • Extension of the risk appetite taking into account the time horizon of sustainability risks, in particular medium and longer-term structural risks in the business model and derivation of suitable KPIs 
  • Integration of E(SG) risks into the main business and management processes e.g., granting of loans
  • Expansion of methodological tools – e.g., ESG scoring, scenario analyses and stress tests, normative and economic perspective in ICAAP
  • Further development of the internal reporting system to include sustainability risks – taking data governance into account
  • Further development of external reporting (Pillar 3 reporting or non-financial reporting)

Tackle the supervisory challenges!

PwC can help you gain a quick and systematic overview of your bank‘s level of preparedness regarding the extensive requirements and regulator´s expectations on climate and environmental or ESG-risks and we can help you to implement ESG risk management.

  • PwC ECB requirements gapping: PwC can help you assess the gaps in your processes and documentation in relation to ECB requirements, enabling you to identify areas for improvement.
  • PwC Road-Maps: PwC has created holistic implementation plans for the implementation of sustainability considerations for various customers.
  • PwC Heatmap: PwC has developed Heatmaps e.g. based on Sustainable development goals for defining and analysing ESG-risk drivers. Heatmaps are used for example as part of materiality assessment.
  • PwC Stress Test: We have already supported banks with the ECB climate stress test. In addition, we supported various banks in the development of internal climate stress tests and used climate risk stress testing tools. As part of our projects, we have dealt in particular with the Network of Central Banks and Supervisors for Greening the Financial System (NGFS ) and other data sources, e.g. for physical risks.
  • PwC ESG Score: PwC develops ESG scores for a banking association and banks. We designed hybrid scorecard by using both external and internal available information. Our ESG scores identify relevant risk factors and are used in addition to evaluating individual loans, e.g. for portfolio analyses, risk appetite statements, strategy and risk management.
  • PwC ESG-Data Tracker: We as PwC are able to help you to identify new data points and for displaying missing data including analysis of required data for the disclosure of ESG risks and efficient identification of the need for action and tracking of project progress and optimizing your disclosure requirements.
  • PwC benchmarks: We draw our extensive experience from numerous projects in the context of ECB banking supervision, the ongoing analysis of regulator´s climate risk letters (e.g., ECB, EBA, ESMA), results of on-site inspections and other ECB pronouncements and, last but not least, from our direct communication with the ECB. This experience helps us to identify supervisory trends at an early stage and, in particular, to read "between the lines" of published supervisory requirements.

Be on par with the ECB!

The ECB holds up a mirror to you - e.g., in Thematic Reviews, Climate Stress Testing and JST´s – and sets clear deadlines for implementation. The supervisory authority has communicated that banks still have a long way to go in terms of the appropriate implementation of ESG aspects in risk management processes.

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Contact us

Martin Neisen

Martin Neisen

Partner, PwC Germany

Tel: +49 151 53800865

Benoît Sureau

Benoît Sureau

Partner, PwC France

Tel: +33 7 72 37 33 32