EBF Response to the Basel Committee’s consultation on a Pillar 3 disclosure framework for climate-related financial risk
March 2024
March 2024
BRUSSELS, 18 March 2024 – The European Banking Federation welcomes the opportunity to respond to the Basel Committee’s consultation on a Pillar 3 disclosure framework for climate-related financial risk. The EBF recognize the critical importance of addressing climate-related risks within the financial sector while ensuring the stability and resilience of the global financial system.
Disclosure frameworks play a crucial role in fostering transparency within the banking sector, enabling investors and stakeholders to assess risks, vulnerabilities, and mitigation strategies. We believe that both quantitative and qualitative information are essential, encompassing traditional as well as climate-related financial risk drivers.
Key points of our response include:
For a comprehensive overview, kindly refer to our full response document.
For more information:
Denisa Avermaete, Senior Policy Adviser – Sustainable Finance, D.Avermaete@ebf.eu
Matilde Quarin, Policy Adviser – Prudential Policy & Supervision, M.Quarin@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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]]>January 2025
Curious about how CSRD data from corporates is used by banks to manage risk?
Discussions on the need to simplify reporting requirements and reduce reporting burdens are ongoing in the context of the upcoming Omnibus initiative of the European Commission. In our recent webinar, we explored what data banks need to manage climate and nature-related risks, and how the data published by corporates under CSRD aligns with these needs. While there is certainly room for streamlining and simplification, some CSRD data is considered critical by banks—regardless of whether it is required by law or not—for understanding inherent and residual risks as well as corporate actions to mitigate these risks.
The recent report published by C-ESG Risk RT provides recommendations on how corporate data could be better focused and structured to improve its comparability and usability for risk management purposes.
We also discussed the use of estimates in the absence of data, how data impacts key processes such as due diligence or customer credit rating, and what a credible corporate transition plan might look like.
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The post Recording of the Launch of the New C-ESG Risk Roundtable Data Workstream Report appeared first on EBF.
]]>December 2024
Brussels, 17 December 2024 – The new report of the Data Workstream of the C-ESG Risk Roundtable (link) explains how the climate change and biodiversity and ecosystems-related disclosures of non-financial corporates under the CSRD could be used by banks for risk management purposes. It presents a starting point for better dialogue between banks and non-financial corporates, ultimately feeding into the results of key processes, such as customer due diligence, customer risk assessments and credit ratings.
Key disclosure requirements
The following types of disclosure requirements by corporates are considered as highly useful for risk assessment and risk management processes of banks:
Assessment of inherent risk:
Risk mitigation actions:
Financial materiality of the residual risk:
Information on the methodology of the performed assessment:
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BRUSSELS, 3 October 2024 – The European Banking Federation (EBF), together with the Association for Financial Markets in Europe (AFME), BVI (German Investment Funds Association), Bundesverband der Wertpapierfirmen (BWF), the European Fund and Asset Management Association (EFAMA) and the International Capital Markets Association (ICMA) released a joint statement on MIFIR RTS 2 post-trade deferrals for bonds.
It follows the respective associations’ responses to the May 2024 ESMA Consultation Paper on the amendment to RTS 2 and is intended to guide ESMA in fulfilling its mandate of drafting regulatory technical standards to support an effective post-trade deferral regime as required by Article 11(4) of MiFIR.
Central to the recommendations offered by the Associations is the importance of ESMA following a credible, balanced and data-driven approach in determining the appropriate calibrations for applying deferrals. The proposal put forward by ESMA in its May 2024 Consultation Paper is not consistent with this approach and, as currently designed, could fail in its objective of creating an effective transparency framework for EU bond markets.
For more information:
Jacopo Borgognone, Senior Policy Adviser – Financing Growth, j.borgognone@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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]]>September 2024
Brussels, 26 September 2024 – The latest report of the C-level ESG Risk Roundtable is a result of the join work of the Climate Physical Risk WS members facilitated by Groupe Crédit Agricole and Société Générale as workstream leaders.
The objective of the report was to collect current practices as well as the common challenges encountered, with the aim to identify possible “quick wins” to overcome the challenges. While initially focused on Pillar 3 disclosures for Environmental, Social and Governance (ESG) risks, the WS discussions extended to cover broader risks management practices, with focus on climate physical risk.
The practices to disclose climate physical risk exposures as part of Pilar 3 ESG differ significantly, due to differences in the reporting format and scope, assessment methodologies and parameters, as well as definition and selection of the hazards, preventing comparison of exposure across banks. The report suggests approaches to overcome the key identified challenges such as hazard definition, categorization and selection.
The report also touches on issue of data sourcing, data inconsistencies as well as scenarios selection and time horizons used. At this stage, WS members recommend greater transparency on scenarios selection and chosen time horizons.
Other topics explored in the report include the challenges related to asset localisation, value chain considerations and the role of insurance in risk identification process.
The WS members intend to continue discussing topics such as assessment of the financial impacts of the climate physical risk for the bank, considerations of mitigation and adaptation measures as well as integration of the climate physical risk in the risk framework.
To read more about the climate physical risks management, the challenges identified, and approaches suggested to overcome the challenges, please refer to the full version of the report.
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]]>January 2024
BRUSSELS, 11 January 2024 – This report is the result of the collaborative work of the Collateral WS (CWS) members, facilitated by Santander in its role as chair of the WS
Key objectives of the CWS:
Key conclusions:
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]]>November 2023
BRUSSELS, 29 November 2023 – This report is a result of the joint work of the WS members facilitated by Nordea Bank Abp in its role as Data WS (DWS) chair. The objective of the report was to identify commonly applied practices for addressing data and methodological uncertainties associated with disclosures against the Implementing Technical Standards (ITS) on prudential disclosures and ESG risks (Pillar 3). Identifying practices across a selection of banks aimed at facilitating more transparent crossbank disclosures by industry, and in doing so mitigate a lack of comparability and/or potential greenwashing for the uncertainties in scope.
The targeted suggestions presented in this report are on a metric-specific level, with the following four metrics of the ITS on Pillar III:
The starting point for all banks seeking to disclose against these and other relevant ESG-related metrics is a low-quality data environment, often mixed with fragmented or limited methodological guidance. Metric specific maturity varies across the industry, which can be explained by the various regulatory disclosure timelines. As banks seek to quantify their exposures for each metric under such uncertainties, the development of disclosure practices remains challenging compounded by limited comparability, impacting risk management, and potentially greenwashing perceptions for internal data or methodological choices.
Despite the observed challenges, participating banks in the DWS were relatively well-aligned in terms of their approaches to the identified challenges to their respective Pillar III disclosures.
As the common practices for all metrics become more established, progress across financial institutions’ disclosures will become inevitable. Banks also believe that methodological guidance may be further developed, focusing on the areas of uncertainty presented in this report.
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BRUSSELS, 29 May 2024 – At the Roundtable on the distribution of retail investment products on 18 July 2023, the European Commissioner for Financial Stability, Financial Services and Capital Markets Union, Mairead McGuinness, invited the European Banking Federation (EBF), the European Fund and Asset Management Association (EFAMA) and Insurance Europe to advance an industry-driven process to explore common solutions aimed at increasing retail participation in EU capital markets.
Responding to the call, EBF, EFAMA and Insurance Europe coordinated a dialogue among financial and insurance industry stakeholders, and reached out to consumer organisations. This discussion paper titled “Charting the Course: Unlocking Retail Investment Participation in the EU” is the outcome of this collaborative effort and was presented at a second Roundtable meeting hosted by the European Commission on 11 April 2024.
The objective of the discussion paper was clear: to explore avenues for increasing European citizens’ participation in capital markets, recognising the dual imperative of economic growth and individual benefit. As underscored by the findings of recent high-level reports, such as those by Mr. Letta and Mr. Noyer, mobilising more savings towards EU capital markets is a necessary objective not just for advancing the Capital Markets Union (CMU), but for financing the long-term competitiveness of the EU as well.
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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]]>May 2024
BRUSSELS, 28 May 2024 – This report is the result of the collaborative work of the Climate Scenario Analysis WorkStream (CSA WS) members, facilitated by BNP Paribas in its role as chair of the CSA WS and with the participation of the ECB and the EBF in an observing capacity. The CSA WS objective is to share, amongst participating banks, the current practices and targeted evolutions on Climate and ESG scenario analysis, internal capital assessment and risk materiality analysis. The initial focus is on Climate and Environmental risk factors. Over 2024, the scope of CSA work will be extended to Biodiversity risk factors and other Environmental concerns.
The understanding of common building blocks as well as discrepancies, including structural differences (due, among other things, to gaps in risk profiles or corporate values), identification of clear challenges with proposed short-term solutions, public dissemination of observed practices and learnings are amongst the key objectives of the CSA WS.
Climate scenario analysis is on the rise.
Recent scientific studies confirm that, without strong action to reduce climate risk, the increase in the frequency and severity of climate events will lead to losses for the economy as a whole and therefore for the financial sector. Moreover, a disorderly or misaligned transition between economic blocs would in particular create shocks to businesses, individuals and, consequently, the financial sector, both as a result of increased credit losses, as well as market shocks and an increase in legal disputes.
Financial supervisory authorities are concerned about both the impact on the safety and soundness of financial institutions as well as the systemic consequences of no or erratic transition. Moreover, the expectations of financial markets and of the various stakeholders are strong in terms of quantifying the financial consequences of the various possible alternatives to date. European supervisors have announced ambitious action plans and are starting to act upon the first steps meticulously.
Financial institutions, such as banks, insurance companies and asset managers, are under pressure, both internally and by their external stakeholders, to communicate on the impact of climate risk factors and to integrate this analysis into the corporate strategy and risk management. This is particularly relevant in Europe, given the relatively consensual alignment of political views on climate goals and the high banking intermediation level (80% of the economy still goes through bank balance sheets).
In a context of extreme uncertainty and significant legal risk, the CSA WS shares a view that the analysis of climate scenarios is a relevant tool for climate risk mitigation as it enables banks to manage risk based on concrete scenarios. Making strategic choices conditional to a given scenario reduce the risk of making unmanageable commitments. While under no obligation to report, disclosing impact analyses based on a set of anchor climate scenarios, financial institutions can limit their responsibility to managing transmission channels towards financial risks to which they are materially exposed.
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BRUSSELS, 11 December 2023 – The EBF recognizes efforts by the European Commission to develop a strong European data economy through initiatives such as the Data Act and Data Governance Act. Under this horizontal framework is the proposed sectoral Regulation on Financial Data Access (FIDA). The proposal aims at promoting data-driven innovation in the financial sector, possibly opening new opportunities for customers while also increasing their control of how and with whom they share data, including through tools such as permission dashboards. Yet the move from open banking to open finance needs very careful consideration, including an appreciation of the potential risks.
We recommend a framework that strikes a balance between mandatory data sharing elements, including the risks, and market-driven elements and sets the right incentives for innovation while maintaining customer trust. We therefore suggest to:
For more information please contact:
Liga Semane
Policy Adviser, Innovation & Data, l.semane@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
The post EBF position on the European Commission’s proposal for a Framework for Financial Data Access (FIDA) appeared first on EBF.
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