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Guide on climate-related

and environmental risks

Supervisory expectations relating to

risk management and disclosure

November 2020

Guide on climate

-related and environmental risks 1

Contents

1 Introduction 3

2 Scope and application 6

2.1 Application to significant institutions 6

2.2 Date of application 7

2.3 Application to less significant institutions 7

2.4 General prudential framework 7

3 Climate-related and environmental risks 10

3.1 Definitions 10

3.2 Characteristics of climate-related and environmental risks 10

3.3 Observations from stocktakes 14

4 Supervisory expectations relating to business models and strategy

16

4.1 Business environment 16

4.2 Business strategy 18

5 Supervisory expectations relating to governance and risk appetite 21

5.1 Management body 21

5.2 Risk appetite 24

5.3 Organisational structure 26

5.4 Reporting 29

6 Supervisory expectations relating to risk management 31

6.1 Risk management framework 31

6.2 Credit risk management 35

6.3 Operational risk management 38

6.4 Market risk management 40

6.5 Scenario analysis and stress testing 42

6.6 Liquidity risk management 43

Guide on climate

-related and environmental risks 2

7 Supervisory expectations relating to disclosures 45

7.1 Disclosure policies and procedures 45

7.2 Content of climate-related and environmental risk disclosures 48

References 51

Guide on climate

-related and environmental risks 3

1 Introduction

Following the adoption of the Paris Agreement on climate change 1 and the UN 2030 Agenda for Sustainable Development in 2015, governments are making strides to transition to low-carbon and more circular economies on a global scale. On the European front, the European Green Deal sets out the objective of making Europe the first climate-neutral continent by 2050. The financial sector is expected to play a key role in this respect, as enshrined in the Commission action plan on financing sustainable growth Transitioning to a low-carbon and more circular economy entails both risks and opportunities for the economy and financial institutions, 2 while physical damage caused by climate change and environmental degrada tion can have a significant impact on the real economy and the financial system. For the second year in a row, the European Central Bank (ECB) has identified climate -related risks as a key risk driver in the SSM Risk Map for the euro area banking system. The ECB is of the view that institutions should take a strategic, forward-looking and comprehensive approach to considering climate -related and environmental risks. The ECB is closely following developments that are likely to affect euro area institutions. The Commission action plan on financing sustainable growth aims to redirect financial flows to sustainable investments, to mainstream sustainability in risk management and to enhance transparency and long -termism. Specifically for the banking sector, the European Banking Authority (EBA) was given several mandates to assess how environmental, social and governance (ESG) risks can be incorporated into the three pillars of prudential supervision. Based on this, the EBA published an

Action Plan on sustainable finance

and a Discussion Paper on the integration of ESG risks into the regulatory and supervisory framework. This guide outlines the ECB's understanding of the safe and prudent management of climate-related and environmental risks under the current prudential framework. It describes h ow the 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 h ow the ECB expects institutions to become more transparent by enhancing their climate -related and environmental disclosures. This guide is not binding for the institutions, but rather it serves as a basis for supervisory dialogue. As part of this superviso ry dialogue, the ECB will discuss with institutions the ECB's expectations set out in this guide in terms of any possible divergences in institutions' practices. The ECB will continue to develop its supervisory 1 Similarly, and following the Global Assessment by the Intergovernmental Science Policy Platform on Biodiversity and Ecosystem Services (IPBES), additional international agreements are expected under

the UN Convention on Biological Diversity to promote the sustainable use of ecosystems and reduce the

causes of biodiversity loss. 2 See, for example, ECB Financial Stability Review May 2019.

Guide on climate

-related and environmental risks 4 approach to managing and disclosing climate -related and environmental risks over time, taking into account regulatory developments, as well as evolving practices in the industry and in the supervisory community. Box 1

Overview of ECB supervisory expectations

1. Institutions are expected to understand the impact of climate-related and environmental risks on

the business environment in which they operate, in the short, medium and long term, in order to be able to make informed strategic and business decisions.

2. When determining and implementing their business strategy, institutions are expected to

integrate climate -related and environmental risks that impact their business environment in the short, medium or long term.

3. The management body is expected to consider climate-related and environmental risks when

developing the institution's overall business strategy, business objectives and risk management framework, and to exercise effective oversight of climate -related and environmental risks.

4. Institutions are expected to explicitly include climate-related and environmental risks in their risk

appetite framework.

5. Institutions are expected to assign responsibility for the management of climate-related and

environmental risks within the organisational structure in accordance with the three lines of defence model.

6. For the purposes of internal reporting, institutions are expected to report aggregated risk data

that reflect their exposures to climate -related and environmental risks with a view to enabling the management body and relevant sub -committees to make informed decisions.

7. Institutions are expected to incorporate climate-related and environmental risks as drivers of

existing risk categories into their existing risk management framework, with a view to managing, monitoring and mitigating these over a sufficiently long-term horizon, and to review their arrangements on a regular basis. Institutions are expected to identify and quantify these risks within their overall process of ensuring capital adequacy.

8. In their credit risk management, institutions are expected to consider climate-related and

environmental risks at all relevant stages of the credit-granting process and to monitor the risks in their portfolios.

9. Institutions are expected to consider how climate-related and environmental events could have

an adverse impact on business continuity and the extent to which the nature of their activities could increase reputational and/or liability risks.

10. Institutions are expected to monitor, on an ongoing basis, the effect of climate-related and

environmental factors on their current market risk positions and future investments, and to develop stress tests that incorporate climate-related and environmental risks.

Guide on climate

-related and environmental risks 5

11. Institutions with material climate-related and environmental risks are expected to evaluate the

appropriateness of their stress testing with a view to incorporating them in to their baseline and adverse scenarios.

12. Institutions are expected to assess whether material climate-related and environmental risks

could cause net cash outflows or depletion of liquidity buffers and, if so, incorporate these factors

into their liquidity risk management and liquidity buffer calibration.

13. For the purposes of their regulatory disclosures, institutions are expected, to publish meaningful

information and key metrics on climate-related and environmental risks that they deem to be material, with due regard to the European Commission's Guidelines on non-financial reporting:

Supplement on reporting climate

-related information.

Guide on climate

-related and environmental risks 6

2 Scope and application

2.1 Application to significant institutions

The expectations set out in this guide are to be used in the ECB's supervisory dialogue with significant institutions directly supervised by the ECB. This guide was developed jointly by the ECB and the national competent authorities (NCAs) with the aim of providing greater transparency regarding the ECB's understanding of sound, effective and comprehensive management, as well as disclosure of climate-related and environmental risks under the current prudential framework. 3

Moreover, it aims to

enhance the industry's awareness of and preparedness for managing climate -related and environmental risks.

The guide does not substitute o

r supersede any applicable law. It should be read in conjunction with other ECB guides and in particular, the ECB Guide to the internal capital adequacy assessment process (ECB Guide to the ICAAP). 4

The supervisory

expectations relate to specific provisions under the Capital Requirements Directive (CRD) 5 and the Capital Requirements Regulation (CRR). 6

Therefore, the level and

scope of consolidation to which each of the supervisory expectations applies follows the same level and scope of application as that of the relevant provision. Significant institutions are expected to use the guide, taking into account the materiality of their exposure to climate -related and environmental risks. For the purposes of this guide, materiality should be considered in the light of the applicable

CRD and CRR provisions.

7 It is worth noting that the assessment of materiality is an institution -specific assessment, taking into account the specificities of the respective business model, operating environment and risk profile. Depending on the business model, operating environment and risk profile, an institution, irrespective of its size, could be concentrated in a market, sector or geograph ic area that is exposed to material physical and transition risks, which means that it could be extremely vulnerable to the impacts of climate -related change and environmental degradation. 8 Furthermore, in addition to this guide and to relevant Union law and national law, institutions are encouraged to duly consider other relevant publications, such as those by the European Commission (EU COM), the EBA, the Network for Greening the 3 This effectively means that this guide does not intend to impose additional auditing requirements. 4 See the Guide to the internal capital adequacy assessment process (ICAAP), ECB, 2018. The current

guide further specifies how the particularities of climate-related and environmental risks are expected to

be taken into account for the management of risks to capital. 5 Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the

activity of credit institutions and the prudential supervision of credit institutions and investment firms,

amending Directive 2002/87/EC and repealing Directive 2006/48/EC and 2006/49/EC (OJ L 176,

27.6.2013, p. 338).

6 Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU)

No 648/2012 (OJ L 176, 27.6.2013, p.1).

7

See also Chapters 6 and 7 of this guide.

8 See the "Guide for Supervisors: Integrating climate-related and environmental risks in prudential supervision ", Technical document, NGFS, May 2020.

Guide on climate

-related and environmental risks 7 Financial System (NGFS), the Basel Committee on Banking Supervision (BCBS), the

Financial Stability Board, the Task Force on

Climate

-related Financial Disclosures (TCFD), the Organisation for Economic Co -operation and Development (OECD) and the NCAs. 9 It should be noted that the examples of observed practices shown in the boxes in this guide merely serve as a means of illustration and are not necessarily replicable, nor do they necessarily meet all supervisory expectations.

2.2 Date of application

This guide is applicable as of its date of publication. Significant institutions are expected to consider the extent to which their curre nt management and disclosure practices for climate -related and environmental risks are sound, effective and comprehensive in the light of the expectations set out in the guide. Where this is needed, significant institutions are expected to promptly start enhancing their practices.

As part of th

e supervisory dialogue, from early 2021, significant institutions will be asked by Joint Supervisory Teams to inform the ECB of any existing divergences in their practices from the supervisory expectations described in this guide and to inform the ECB of arrangements aimed at progressively addressing these expectations. The ECB acknowledges that the management and disclosure of climate -related and environmental risks, and also the methodologies and tools used to address them, are currently evolving and are expected to mature over time.

2.3 Application to less significant institutions

This guide was developed jointly by the ECB and the NCAs and is aimed at ensuring the consistent application of high supervisory standards a cross the euro area. NCAs are therefore recommended to apply the expectations set out in this guide in their supervision of less significant institutions in a manner that is proportionate to the nature, scale and complexity of the activities of the institution concerned. The ECB acknowledges that a number of NCAs have issued, or are in the process of issuing, guidance on climate -related and environmental risks. Less significant institutions are invited to consider these as well as other relevant publication s by their NCAs.

2.4 General prudential framework

This guide describes the ECB's understanding of

sound, effective and comprehensive management and disclosure of climate-related and environmental risks under the 9

See, for instance, "Guidance Notice on Dealing with Sustainability Risks", BaFin, 2019, "Integration of

climate-related risk considerations into banks' risk management", Good Practice document, DNB, 2020, and "Guide for Handling Sustainability Risks",

Consultation document, FMA, 2020.

Guide on climate

-related and environmental risks 8 current prudential framework. In that respect, the following articles under the CRD and the CRR are of particular relevance: Article 73 CRD requires institutions to have in place sound, effective and comprehensive strategies and processes to assess and maintain on an ongoing basis the amounts, types and distribution of internal capital that they consider adequate to cover the nature and level of the risks to which they are or might be exposed. Article 74(1) CRD requires institutions to have robust governance arrangements, which include a clear organisational structure with well-defined, transparent and consistent lines of responsibility, effective processes to identify, manage, monitor and report the risks they are or might be exposed to, adequate internal control mechanisms, including sound administratio n and accounting procedures, and remuneration policies and practices that are consistent with and promote sound and effective risk management. Article 74(2) CRD provides that the arrangements, processes and mechanisms referred to in paragraph

1 shall be comprehensive and proportionate to the

nature, scale and complexity of the risks inherent in the business model and the institution's activities. The technical criteria established in Articles 76 to 95 shall be taken into account. Article 76(1) CRD requires institutions to ensure that the management body approves and periodically reviews the strategies and policies for taking up, managing, monitoring and mitigating the risks the institution is or might be exposed to, including those posed by the macroe conomic environment in which it operates in relation to the status of the business cycle. Article 79 CRD sets out specific legislative requirements for credit and counterparty risks that the competent authorities must ensure are in place vis-à-vis credit institutions. Article 83(1) CRD provides that competent authorities shall ensure that policies and processes for the identification, measurement and management of all material sources and effects of market risks are implemented. Article 85 CRD provides that competent authorities shall ensure that institutions implement policies and processes to evaluate and manage the exposure to operational risk, [...] including that contingency and business continuity plans are in place to ensure an institution's ability to operate on an ongoing basis and limit losses in the event of severe business disruption. Article 91 CRD provides that [...] members of the management body shall possess sufficient knowledge, skills and experience to perform their duties [...]. Article 431(3) CRR requires institutions to adopt a formal policy to comply with the disclosure requirements laid down in Part Eight [of the CRR] and have policies for assessing the appropriateness of their disclosures, including their verification and frequency. Institutions shall also have policies for assessing

Guide on climate

-related and environmental risks 9 whether their disclosures convey their risk profile comprehensively to market participants. Article 432(1) CRR provides that institutions may omit one or more of the disclosures listed in Title II if the information provided by such disclosures is not regarded as material, except for the disclosures laid down in Article 435(2)(c), Article 437 and Article 450. Information in disclosures shall be regarded as material if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions. The EBA has adopted several guidelines specifying the abovementioned articles. Where this guide makes reference to those guidelines, the reference should be read in conjunction with the relevant articles of the CRD/CRR to which they refer. The following EBA Guidelines are of particular relevance: Committee of European Banking Supervisors (CEBS) Guidelines on liquidity cost benefit allocation of 27 October 2010; EBA Guidelines on internal governance (EBA/GL/2017/11); Joint ESMA and EBA Guidelines on the assessment of the suitability of members of the management body and key function holders under Directive 2013/36/EU and Directive 2014/65/EU (EBA/GL/2017/12); EBA Guidelines on the revised common procedures and methodologies for the supervisory review and evaluation process (SREP) and supervisory stress testing (EBA/GL/2018/03); EBA Guidelines on institutions' stress testing (EBA/GL/2018/04); EBA Guidelines on sound remuneration policies under Articles 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU)

No 575/2013 (EBA/GL/2015/22);

EBA Guidelines on materiality, proprietary and confidentiality and on disclosure frequency under Articles 432(1), 432(2) and 433 of Regulation (EU)

No 575/2013(EBA/GL/2014/14);

EBA Guidelines on outsourcing arrangements (EBA/GL/2019/02); EBA Guidelines on loan origination and monitoring (EBA/GL/2020/06).

Guide on climate

-related and environmental risks 10

3 Climate-related and environmental risks

3.1 Definitions

Climate change and environmental degradation are sources of structural change that affect economic activity and, in turn, the financial system. Climate -related and environmental risks are commonly understood to comprise two main risk drivers: Physical risk refers to the financial impact of a changing climate, including more frequent extreme weather events and gradual changes in climate, as well as of environmental degradation, such as air, water and land pollution, water stress, biodiversity loss and defore station. 10

Physical risk is therefore categorised as

"acute" when it arises from extreme events, such as droughts, floods and storms, and "chronic" when it arises from progressive shifts, such as increasing temperatures, sea -level rises, water stress, biodiversity loss, land use change, habitat destruction and resource scarcity. 11

This can directly result in, for

example, damage to property or reduced productivity, or indirectly lead to subsequent events, such as the disruption of supply chains. Transition risk refers to an institution's financial loss that can result, directly or indirectly, from the process of adjustment towards a lower-carbon and more environmentally sustainable economy. This could be triggered, for example, by a relatively abrupt adoption of climate and environmental policies, technological progress or changes in market sentiment and preferences.

3.2 Characteristics of climate-related and environmental risks

Physical and transition risk drivers impact economic activities, which in turn impact the financial system. This impact can occur directly, through for example lower corporate profitability or the devaluation of assets, or indirectly, through macro -financial changes. 12 These risks also affect the resilience of an institution's business model over the medium to long er term, and predominantly those institutions with business models that are reliant on sectors and markets which are particularly vulnerable to climate-related and environmental risks. In addition, physical and transition risks can t rigger further losses, stemming directly or indirectly from legal claims (commonly 10 See the "Guide for Supervisors: Integrating climate-related and environmental risks in prudential supervision ", Technical document, NGFS, May 2020. 11

See "Values at risk? Sustainability risks and goals in the Dutch financial sector", Report, DNB, 2019;

"Indebted to nature: Exploring biodiversity risks for the Dutch financial sector'', Report, DNB, June 2020;

and the "Guide for Supervisors: Integrating climate-related and environmental risks in prudential supervision ", Technical document, NGFS, May 2020. 12 While climate-related change and environmental degradation can give rise to microprudential and

macroprudential risk, it should be noted that this guide is prepared by the ECB in the context of the task

conferred to it under the relevant SSM regulation and is therefore limited to microprudential risk.

Guide on climate

-related and environmental risks 11 referred to as "liability risk" 13 ) and reputational loss as a result of the public, the institution 's counterparties and/or investors associating the institution with adverse environmental impacts ("reputational risk"). Consequently, physical and transition risks are drivers of existing risk, in particular credit risk, operational risk, market risk and liquidity risk, as well as non-Pillar 1 risks such as migration risk, credit spread risk in the banking book, real estate risk and strategic risk (see Table 1). Climate-related and environmental risks may, in fact, be drivers of several different risk categories and sub-categories of existing risk categories simultaneously. The magnitude and distribution of physical and transition risks depend on the level and timing of mitigation measures and whether the transition occurs in an orderly or disorderly fashion. Potential losses stemming from climate -related and environmental risks depend especially on the future adoption of climate-related and environmental policies, technological developments and changes in consumer preferences and market sentiment. Irrespective of this, some combination of physical and transition risks will, in all probability, materialise on the balance sheets of euro area institutions and the economic value of their exposures. 14

Existing estimates of adverse long-term

macroeconomic effects resulting from climate change point to significant and lasting losses in wealth. These may be due to slowing investment and lower factor productivity in many sectors of the economy, as well as reduced potential GDPquotesdbs_dbs30.pdfusesText_36

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