Climate transition plans for banks: European legislators on a razor’s edge
The proposal for mandatory climate transition plans for banks is slowly making its way through the regulatory debate. Proposed by the European Commission and confirmed by the EU Council, this proposal has now also been taken up by the European Parliament. This obligation could be a game-changer for financial risk management and the alignment of financial flows with the transition to a low-carbon economy. It could lead banks to limit their activities in climate-damaging activities, adjust their business models, review their strategies as well as their governance and risk management procedures.
But at this stage, while the principle of transition plans exists in the three positions of the Commission, the Council and the Parliament, the exact wording differs in terms of ambition and clarity. In order for these plans to make a real difference, three key parameters will need to be clarified in the trialogue negotiations.
The first parameter is the nature of these mandatory climate transition plans. If the obligation is limited to transparency requirements, the focus will be on the need to publish a plan and not on the need to actually implement it. This is one of the problems with, for example, transition plans adopted voluntarily by financial institutions. Conversely, if banking supervisors are given the mandate to monitor these transition plans as part of the Supervisory Review and Evaluation Process (SREP), they will have several tools at their disposal to ensure their proper implementation.
