EBF response to BCBS Consultation ‘Principles for the effective management and supervision of climate-related financial risks’

X

BRUSSELS, 15 February 2022 – The EBF has responded to the BCBS Consultation on the ‘Principles for the effective management and supervision of climate-related financial risks’. Key messages from the EBF response:

• Support for the ongoing efforts of banks and regulators to ensure proper identification, understanding management, and supervision of risk stemming from climate-related factors. Management, transformation, and absorption of financial risks will be a key element in the transformation of the global economy to net zero as substantial investments e.g. in new technologies need to be financed. Where material risks exist, it must be up to the institution to cover or mitigate them in line with their own business strategy and risk appetite. The role of supervisors should be to ensure that such risks are considered by the institutions, identified, understood, and managed.

• Welcome the Basel Committee‘s focus is on the risks associated with climate change, not the banks’ action to tackle climate change. Banks’ shifting of resources towards a low-carbon economy and engagement with customers is key in financing the transition. While banks are fully aware of their responsibilities and are committed to playing their role, it is not realistic to expect financial services to make this shift in the absence of a major change in the incentives of the underlying economy. The climate objectives must be transposed in the industrial policies and relevant national legal frameworks. Banks cannot be put in the position of being the primary enforcers of climate policy, nor should the prudential framework be used as a substitute for direct mechanisms such as taxes or industrial measures.

• Balance harmonization efforts at the global level with existing methodological flexibility. We welcome harmonization efforts at the global level and believe the principles of the Basel Committee have to be respected by national/regional authorities. However, as several authorities have already issued their supervisory expectations for climate-related risk management by banks the current flexibility in terms of methodologies as well as proportionality needs to be maintained over time given the large-scale investments required for the development of methodologies and internal systems. Global harmonization and streamlining are in particular essential for reporting and disclosures requirements. Harmonization and alignment of data definitions are needed, ideally at a global level not only to address reporting burden but also to prevent market confusion to avoid multiple reporting obligations or reporting of similar but slightly different information given in response to diverging regulatory requests and definitions.

• Capital should be determined with risk-sensitive metrics but it is too early for quantitative impact on the capital . At this stage, however, the relationship between risk drivers and actual risk levels on capital has not been established yet. Current risk measure models are not developed for a long-time horizon, the underlying capital planning likewise cannot be designed to take capital decisions in 30 years as the uncertainty increases based on accumulating assumptions. There are still a lot of uncertainties as to the evolution of physical and transition climate risk drivers coupled with a lack of reliable data and statistical data elements as well as lack of skills and methodologies to understand the expected impact given the interrelation between physical risks and transition risks respective evolutions (according to climate policies, technology, investor and consumer behavior, etc.) and the non-linear, incremental nature of physical risks over time in particular. Scenario analyses are also still in a pilot stage and will become more sophisticated over time. Stress testing methodologies for ESG risks have so far mainly been applied in an exploratory manner. While some assumptions and simplifications are needed so that the exercises are doable given the current limitations regarding data and methodologies, the framework and its results might be unrealistic, and special care has to be taken when analyzing the results. Therefore, as long as data, methodologies, and results of regulatory stress testing exercises are not stabilized, these exercises should not imply any quantitative impact on the capital requirement of the entities. Qualitative impacts in the supervisory review process should be restricted to very limited cases (for example, where it is unequivocal that a bank has not started to set up the governance and internal processes to integrate and account for climate-related financial risks). Climate-related stress testing should also be kept separate from “regular” stress testing.

• A phased-in approach as a way forward. Given the current lack of available quality data, harmonized definitions, and forward-looking risk methodologies to assess the impact of climate-related risk on existing risk categories we believe it is necessary to underline the need for a phase-in approach for banks