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ECB

ECB

High Impact

ECB final guide sets supervisory expectations for banks’ climate-related and environmental risk management and disclosures

Published

Jul 2, 2026

Topics

Climate-related financial risk, Environmental risk, Risk management, Governance, ICAAP, Stress testing, Credit risk, Operational risk, Market risk, Liquidity risk, Pillar 3 and regulatory disclosures

Executive Summary

The ECB has finalised its Guide on climate-related and environmental risks, setting out 13 supervisory expectations for how banks should identify, manage, monitor and disclose climate and environmental risks within the existing CRD/CRR prudential framework. The guide applies directly to significant institutions supervised by the ECB and is recommended for proportionate use by national competent authorities for less significant institutions. It is not legally binding and does not replace applicable law, but it is expressly intended to frame supervisory dialogue, including bank-by-bank discussions on gaps against ECB expectations. The guide treats physical and transition risks as drivers of existing risk categories rather than as a separate prudential risk type. Banks are expected to embed these risks into business strategy, governance, risk appetite, internal reporting, ICAAP, credit underwriting, collateral valuation, operational resilience, market risk monitoring, liquidity management, stress testing and regulatory disclosures. Subsequent ECB communications confirmed phased supervisory deadlines through 2024, increasing implementation urgency for directly supervised banks.

What Changed

newSupervisory expectations for significant institutions

Previous

Before the final guide, ECB expectations were not consolidated in a single final supervisory guide for climate-related and environmental risk management and disclosure.

New

Significant institutions are expected to assess current practices against the guide and promptly start enhancing practices where gaps exist.

newClimate and environmental risks as drivers of existing prudential risks

Previous

Climate-related and environmental risks were often addressed through corporate social responsibility or sustainability policies rather than integrated prudential risk management.

New

Banks are expected to identify, quantify, monitor and mitigate these risks within existing risk categories, including capital adequacy processes.

newGovernance, risk appetite and internal reporting expectations

Previous

The ECB observed heterogeneous practices and limited incorporation of climate-related risks into risk appetite, stress testing and capital assessment.

New

Banks are expected to define responsibilities across the three lines of defence, set relevant indicators and limits, and integrate climate risk data into management reporting.

newRisk management, ICAAP and stress testing integration

Previous

Only a small number of institutions had fully incorporated climate-related and environmental risks into risk measurement, risk appetite, stress testing or capital adequacy assessment.

New

Institutions with material exposures are expected to evaluate and incorporate these risks into baseline and adverse scenarios and capital adequacy assessment.

newEnhanced disclosure expectations

Previous

ECB assessment found sparse and heterogeneous public disclosure practices, with few institutions transparent on definitions and methodologies.

New

Banks are expected to establish disclosure policies and procedures and publish meaningful climate-related and environmental risk information where material.

Business Impact

Who is affected

Directly affected

significant institutions directly supervised by the ECB, including banking groups within the euro area SSM perimeter.

Indirectly affected

less significant institutions supervised by national competent authorities, EU banking subsidiaries and branches within affected groups, borrowers in climate-sensitive sectors, data providers, valuation providers, outsourcing providers, auditors and disclosure teams.

Jurisdictions

Euro area, European Union

Business processes

Business strategy and business model assessment, Management body governance and committee oversight, Risk appetite statement and limit framework, Risk inventory, ICAAP and capital adequacy assessment, Credit origination, credit monitoring and collateral valuation, Operational resilience and business continuity management, Market risk, liquidity risk and stress testing, Regulatory and public disclosure controls

Estimated effort

High

Compliance risk

High

Affected Reports

ICAAP documentation and capital adequacy assessmentRisk appetite statement, risk inventory and limit frameworkManagement body and risk committee MI on climate-related and environmental risk exposuresCredit policies, underwriting files and portfolio concentration monitoringCRR Part Eight / Pillar 3 and related climate-risk public disclosure controls
FieldValidation rule
Risk inventory: climate-related and environmental risk driversBanks are expected to clearly define climate-related and environmental risks in their risk taxonomy and risk inventory, including physical and transition risk drivers.
Risk appetite indicators and limitsInstitutions are expected to develop appropriate key risk indicators and limits for climate-related and environmental risks, using quantitative metrics where possible and qualitative statements as an intermediate step.
Internal risk reporting: aggregated exposure dataInternal reporting is expected to include aggregated risk data reflecting exposures to climate-related and environmental risks for management body and committee decision-making.
Credit assessment: borrower climate and environmental vulnerabilityCredit processes are expected to identify and assess climate-related and environmental factors material to borrower default risk and creditworthiness.
Collateral valuation: physical location and energy efficiencyCollateral valuation and review processes are expected to consider climate-related and environmental risks, including physical location and energy efficiency of commercial and residential real estate.

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    Confirmed actionStep 1 of 7

    perform a documented gap assessment against the ECB’s 13 expectations and maintain evidence of remediation for supervisory dialogue.

  2. 2
    Confirmed actionStep 2 of 7

    integrate physical and transition risk drivers into the risk taxonomy, risk inventory, ICAAP, risk appetite framework and internal reporting rather than treating them only as sustainability or CSR topics.

  3. 3
    Confirmed actionStep 3 of 7

    ensure the management body has clear responsibilities, receives decision-useful climate risk MI, and oversees strategy, risk appetite and remediation progress.

  4. 4
    Confirmed actionStep 4 of 7

    update credit origination, monitoring, concentration analysis and collateral valuation procedures to capture material climate-related and environmental risks.

  5. 5
    Confirmed actionStep 5 of 7

    assess whether material risks should be incorporated into baseline and adverse stress-testing scenarios, capital planning and liquidity risk management.

  6. 6
    AI generatedStep 6 of 7

    prioritise data architecture for sector, geography, collateral, emissions, energy-performance and counterparty transition-plan data, with documented data limitations and interim proxies.

  7. 7
    AI generatedStep 7 of 7

    align public disclosures with internal materiality assessments and maintain controls over definitions, methodologies, metrics and governance sign-off.

Timeline

publication

May 2020

ECB published a draft guide on climate-related and environmental risks for public consultation.

publication

Nov 2020

ECB published the final Guide on climate-related and environmental risks. The guide states it is applicable as of its publication date.

effective date

Nov 2020

Significant institutions were expected to consider whether their practices were sound, effective and comprehensive in light of the guide and to promptly start enhancements where needed.

implementation

2021

From early 2021, Joint Supervisory Teams were to ask significant institutions to inform the ECB of divergences from the guide and arrangements to progressively address expectations.

publication

Nov 2, 2022

ECB announced staggered supervisory deadlines for banks to progressively meet the 2020 guide’s expectations.

implementation

Mar 31, 2023

ECB deadline for banks to adequately categorise climate and environmental risks and conduct a full assessment of their impact on bank activities.

implementation

Dec 31, 2023

ECB deadline for banks to include climate and environmental risks in governance, strategy and risk management.

implementation

Dec 31, 2024

ECB deadline for banks to meet all remaining supervisory expectations on climate-related and environmental risks, including full integration in ICAAP and stress testing.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

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