Prudential transition plans: what’s next after the adoption of the Capital Requirements Directive?

Climate change does not conform to business, political or supervisory regime cycles– its adverse long-term impacts lie beyond such horizons. Ten years ago, when Mark Carney highlighted this paradox in his landmark Tragedy of the Horizons speech, climate change was not considered a financial stability risk. Today, European supervisory stress tests estimate up to €638 billion in banking losses over 8 years, while the European Central Bank (ECB) reveals that over 90% of eurozone banks face climate and environmental risks. A key question arises: Is the supervisors’ primary focus on greening the financial system sufficient in the face of rising risks, especially stranded assets? 

Integrating climate indicators into variable remuneration is a burning issue. Although it was removed at the last minute from negotiations on the Corporate Sustainability Due Diligence Directive (CSDDD), the proposal is still very much alive in the policy debate . While the topic is becoming increasingly central to remuneration in large companies, it still appears to be a taboo within the banking sector. This requirement was already included in the European Central Bank’s supervisory guidelines as early as 2020, yet it appears to have been largely neglected by banks.

The President of the European Commission, Ursula von der Leyen, has committed to presenting a European Climate Adaptation Plan in 2026. The European Commission has previously emphasised public budgets as the main source of coverage for climate-related disasters. But if both the EU’s and member states’ budgets are strained by competing investment priorities and high debt levels in some cases, what are the complementary avenues for financing adaptation in the EU? How can private financial actors, such as banks, insurance companies or asset management firms, support adaptation efforts, not only to ensure resilience (i.e. recovery) from climate disasters, but also to prevent impacts before they arrive?