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.”
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)
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)
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
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:
1 |
|
2 |
|
3 |
|
4 |
|
5 |
|
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.
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.
We can support you in the transformation with our experience and global network!