ESRB Report Examines Effective Tools for Carbon Emission Reduction
The European Systemic Risk Board (ESRB) published a report that analyzes whether bank capital requirements can be an effective tool to reduce carbon emissions and deal with prudential risks arising from climate change.
The report on bank capital regulation and climate change discusses whether and how monetary policy and financial regulation should take climate change and the associated risks into account. The report focuses on the bank capital regulation and examines that the climate change could be relevant for bank regulators in two possible scenarios. In the first scenario, climate change may expose the banking sector to financial risks that the current regulatory framework does not account for. Prudential capital requirements based on historical default frequencies are unlikely to fully account for future physical and transition risks arising from climate change. In the second scenario, bank capital regulation may be proposed as a tool for tackling the consequences of climate change more broadly by supporting the transition to a low-carbon economy, as no global carbon tax has been implemented.
The report concludes that, while bank capital requirements can effectively address prudential risks arising from climate change, they are not likely to be the most effective tool for reducing carbon emissions. The report states that using capital requirements to address climate risks is similar to managing traditional risks. However, in contrast to traditional risks, climate risks pose novel measurement challenges, because historical data series contain limited information about future climate risks. Despite the recent progress in the form of climate stress tests and other research, more work needs to be done to understand the exposure of the financial sector to climate risks, some of which will materialize over a time horizon that exceeds the horizon usually considered for prudential regulation. The report also highlights that using bank capital requirements to discourage funding of carbon-intensive activities is less likely to be effective for two reasons. The first one states that, as long as activities with high carbon emissions remain profitable, removing loans that fund these activities from the banking sector may either be impossible or may require lowering capital requirements on loans with small carbon footprints below the prudentially optimal level, thus sacrificing financial stability. The second reason sates that, even if capital regulation can successfully remove dirty loans from the banking system, high-emitting activities will likely attract funding elsewhere as long as they offer a positive return to investors.
The report suggests that bank capital requirements can play a supporting role by facilitating more direct policy measures. Carbon taxes, one such measure that can directly reduce the profitability of carbon-intensive investments, could be more effective to reduce emissions and the associated externalities. By ensuring sufficient loss-absorbing capital in the banking sector, bank capital requirements can help to facilitate the introduction of carbon taxes or stricter environmental regulation, which governments may be reluctant to introduce so long as the resulting revaluation of bank assets and the associated stranded asset risk could trigger a banking crisis.
Related Link: Report (PDF)
Keywords: Europe, EU, Banking, Climate Change Risk, Basel, Regulatory Capital, Low Carbon Economy, Carbon Tax, ESG, ESRB
Featured Experts

María Cañamero
Skilled market researcher; growth strategist; successful go-to-market campaign developer

Nicolas Degruson
Works with financial institutions, regulatory experts, business analysts, product managers, and software engineers to drive regulatory solutions across the globe.

Patrycja Oleksza
Applies proficiency and knowledge to regulatory capital and reporting analysis and coordinates business and product strategies in the banking technology area
Previous Article
SRB Sets Out Work Priorities for 2023Related Articles
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.
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.
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.
DNB Publishes Multiple Reporting Updates for Banks
DNB, the central bank of Netherlands, updated the list of additional reporting requests and published additional data quality checks and XBRL-Formula linkbase documents for the first quarter of 2023.
NBB Sets Out Climate Risk Expectations, Issues Reporting Updates
The National Bank of Belgium (NBB) published a communication on climate-related and environmental risks, issued an update on XBRL reporting
EBA Updates Address Securitization Standards and DGS Guidelines
The European Banking Authority (EBA) published the final draft of the regulatory technical standards that set out conditions for assessment of homogeneity of the underlying exposures in simple, transparent, and standardized (STS) securitizations.
FSB Publishes Letter to G20, Sets Out Work Priorities for 2023
The Financial Stability Board (FSB) published a letter intended for the G20 Finance Ministers and Central Bank Governors, highlighting the work that FSB will take forward under the Indian G20 Presidency in 2023