The EU ETS’ market stability reserve: a marginal long-term structural reform

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? 

The climate and development finance gap is large and widening, as Official Development Assistance (ODA) declines and needs multiply. With shrinking fiscal space in vulnerable countries, solidarity levies are gaining attention as a predictable source of international finance. Launched at COP28 by Barbados, France, and Kenya, the Global Solidarity Levies Task Force (GSLTF) is the main initiative in this space.

National Public Banks (NPBs) and Subnational Public Financial Institutions (SPFIs), including development banks and agencies as well as climate and green funds at the subnational level, play an increasingly vital role in financing climate action and the just transition. While national governments provide frameworks aligned with nationally determined contributions (NDCs), actual implementation occurs largely at the subnational level, which currently lacks sufficient funding. SPFIs can work as financial intermediaries, as they not only understand local needs and have stronger ties with local governments and businesses, but also access much larger volumes of capital from more diverse sources.