ECB and MFSA Review Bank Preparations for Addressing Climate Risks
The European Central Bank (ECB) and the Malta Financial Services Authority (MFSA) recently reviewed the preparations banks are making to assess and mitigate the risks posed by climate change to their business models. In a Circular, MFSA has published the results of this review for the less significant banks, notes the areas in which further work is required, and has requested banks to accelerate their preparations and present the progress.
MFSA concluded that all banks in Malta need to strengthen their governance arrangements by engaging with their customers to collect data so they can meet their disclosure obligations, by improving their understanding of climate-related and environmental risks, and by putting in clearer plans to assess climate-related risks and integrate them into their risk management frameworks. The review aimed to assess the soundness, effectiveness, and comprehensiveness of climate-related and environmental risk management practices of banks and align them with them the ECB guidance (of November 2020) on climate-related and environmental risks. The review notes that:
- Banks in Malta are in the very early stages of taking steps to integrate climate-related and environmental risk into their risk management frameworks. Therefore, increased momentum will be needed so that banks hit the expected legislative deadlines.
- When evaluating the existence and quality of practices for climate-related and environmental risks, some banks have initiated a few basic practices on climate-related and environmental risks but there is a lot of work to do to move beyond the first phase of preparation.
- Climate-related and environmental risk practices do not yet comprehensively consider the main portfolios and business lines of banks as well as the sectors and the geographies in which they are active.
- Banks do not have systems to evaluate relevant risk drivers such as the impact of market forces, including technology on transition risks. Similarly, banks do not yet map the physical risk impact to financial risks.
- Banks need to develop mechanisms to consider the various time horizons over which risks can materialize.
- Some banks informed MFSA about plans to align themselves with the ECB guide, though these plans have not yet been "actioned."
Related Link: Thematic Review Circular (PDF)
Keywords: Malta, Banking, ESG, Europe, MFSA, Climate Change Risk, ECB
Featured Experts

James Partridge
Credit analytics expert helping clients understand, develop, and implement credit models for origination, monitoring, and regulatory reporting.

Michael Denton, PhD, PE
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
Previous Article
NBB Maintains CCyB for Banks at 0%, Issues Other UpdatesRelated Articles
FINMA Approves Merger of Credit Suisse and UBS
The Swiss Financial Market Supervisory Authority (FINMA) has approved the takeover of Credit Suisse by UBS.
BOE Sets Out Its Thinking on Regulatory Capital and Climate Risks
The Bank of England (BOE) published a working paper that aims to understand the climate-related disclosures of UK financial institutions.
OSFI Finalizes on Climate Risk Guideline, Issues Other Updates
The Office of the Superintendent of Financial Institutions (OSFI) is seeking comments, until May 31, 2023, on the draft guideline on culture and behavior risk, with final guideline expected by the end of 2023.
APRA Assesses Macro-Prudential Policy Settings, Issues Other Updates
The Australian Prudential Regulation Authority (APRA) published an information paper that assesses its macro-prudential policy settings aimed at promoting stability at a systemic level.
BIS Paper Examines Impact of Greenhouse Gas Emissions on Lending
BIS issued a paper that investigates the effect of the greenhouse gas, or GHG, emissions of firms on bank loans using bank–firm matched data of Japanese listed firms from 2006 to 2018.
HMT Mulls Alignment of Ring-Fencing and Resolution Regimes for Banks
The HM Treasury (HMT) is seeking evidence, until May 07, 2023, on practicalities of aligning the ring-fencing and the banking resolution regimes for banks.
MFSA Sets Out Supervisory Priorities, Issues Reporting Updates
The Malta Financial Services Authority (MFSA) outlined its supervisory priorities for 2023
German Regulators Issue Multiple Reporting Updates for Banks
Deutsche Bundesbank published the nationally deactivated validation rules for the German Commercial Code (HGB) users on the taxonomy 3.2, which became valid from December 31, 2022
BCBS Report Examines Impact of Basel III Framework for Banks
The Basel Committee on Banking Supervision (BCBS) published results of the Basel III monitoring exercise based on the June 30, 2022 data.
PRA Consults on Prudential Rules for "Simpler-Regime" Firms
Among the recent regulatory updates from UK authorities, a key development is the first-phase consultation, from the Prudential Regulation Authority (PRA), on simplifications to the prudential framework that would apply to the simpler-regime firms.