Submitted:
03 August 2025
Posted:
04 August 2025
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Abstract
Keywords:
1. Introduction
2. Literature Review
2.1. Evolution of Climate Scenarios in Science and Policy
2.2. Climate Risk and the Financial Sector
2.3. The Role of NGFS, ECB, and EBA in Scenario Development and Regulation
2.4. Methodological Challenges in Climate Scenario Integration
3. Methodology
3.1. Research Design and Approach
3.2. Selection of Case Studies
3.3. Data Sources
3.4. Analytical Framework
4. Results and Discussion
4.1. Climate Stress Testing: A Core Application Area
- Around 60% of banks had not yet developed a climate risk stress testing framework internally.
- Over €70 billion in potential losses were estimated under the adverse scenario over a 30-year time horizon , driven mainly by transition risk in high-emission sectors (ECB, 2022).
- Over 20% of banks reported high exposure to carbon-intensive sectors , such as fossil fuels, transportation, and heavy industry.
- Credit portfolios showed limited sectoral diversification , increasing systemic vulnerabilities in the event of disorderly policy transitions.
4.2. Technological and Analytical Tools Supporting Scenario Integration
- Map portfolio alignment with Net Zero trajectories;
- Estimated carbon intensity at issuer and portfolio levels;
- Simulated policy pathways and their economic-financial impact.
4.3. Broader Applicability Across the Financial System
4.4. Empirical Evidence of Climate Intensification
4.5. Critical Appraisal of Current Stress Testing Practices
- Underestimation of tail risks , particularly low-probability, high-impact events known as “Green Swan” events (BIS, 2020; SSRN, 2023 );
- Limited data granularity , especially in emerging markets or for small-to-medium banks lacking climate data infrastructure;
- Inconsistent methodologies across jurisdictions (eg, scenario assumptions, time horizons, valuation metrics), which impedes cross-country comparability;
- Difficulty translating long-term scenario results into short-term financial planning , which constrains managerial actionability (ECB, 2022; EBA, 2022 );
- Inadequate modeling of feedback loops between the real economy, the environment, and the financial system.



5. Recommendations and Practical Steps for Enhancing the Implementation of Climate Scenarios and Stress Testing
Strategic Recommendations
- Advance sector- and region-specific modeling methodologies by developing granular and calibrated tools that reflect differentiated climate exposure across geographies and industries.
- Improve data quality and accessibility through institutional partnerships between public authorities, academic institutions, and the private sector. Harmonized climate and financial datasets are essential for robust scenario construction.
- Incorporate dynamic modeling frameworks , including feedback loops between the financial system, the economy, and environmental variables, to capture the complexity of climate impacts.
- Establish harmonized disclosure and benchmarking frameworks , aligned with the guidelines of the Network for Greening the Financial System (NGFS) and the Task Force on Climate-Related Financial Disclosures (TCFD), to enable comparability and transparency across institutions.
- Strengthen climate competence within the financial sector by investing in specialized training for risk managers, analysts, and supervisors. Capacity building is essential to interpret scenario outputs and translate them into strategic actions.
- Adopt proactive transition strategies , embedded at the board and executive levels, to ensure climate-related risks are considered in all phases of business planning, risk appetite setting, and capital allocation.
Operational Implementation Steps
- Clearly define governance responsibilities related to climate risk within the bank’s organizational structure, assigning oversight to executive leadership and dedicated committees.
- Select and calibrate NGFS climate scenarios that are relevant to the institution’s business model, geographic exposure, and value chain, ensuring contextual sensitivity.
- Develop financial risk models that assess the impact of physical and transition risks on credit, market, and operational exposures across various time horizons.
- Periodically conduct climate stress tests , integrating results into the institution’s capital planning, ICAAP frameworks, and business continuity strategies.
- Establish transparent reporting mechanisms to communicate climate risk exposures, scenario results, and mitigation actions to regulators, shareholders, and the broader public.
- Continuously update scenarios and assumptions based on evolving climate science, policy developments, and technological advancements.
- Adopt a dynamic and forward-looking risk posture , which includes concrete de-risking measures such as portfolio rebalancing, strategic divestment, or green lending policies.
6. Conclusions, Limitations, and Directions for Future Research
Conclusions
Limitations of the Study
- Lack of original empirical modeling : The analysis relies on secondary data and case studies rather than proprietary stress test simulations or econometric models.
- Institutional bias : The study focuses primarily on European institutions (ECB, EBA, NGFS), potentially overlooking unique approaches from emerging markets or non-European jurisdictions.
- Temporal limitations : The fast-evolving nature of climate risk frameworks means that some findings may become outdated as methodologies improve or new regulatory mandates are introduced.
- Limited granularity : Sector-specific impacts are discussed at an aggregated level; further disaggregation by bank type, region, or size would enhance the applicability of insights.
Directions for Future Research
- Developing quantitative stress testing models that simulate climate risk transmission channels using real banking data, particularly in emerging and developing economies.
- Exploring behavioral responses of financial institutions and regulators to climate scenarios, including risk aversion, capital allocation, and governance shifts.
- Assessing the effectiveness of scenario-based strategies in actually reducing portfolio-level emissions or reorienting credit towards green investments.
- Comparing jurisdictional approaches to climate stress testing to identify best practices and gaps in international coordination.
- Integrating socio-economic variables such as inequality, labor market shifts, and regional vulnerability into stress testing models to better reflect systemic impacts.
References
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- Batten, S.; Sowerbutts, R.; Tanaka, M. (2016). Let’s talk about the weather: The impact of climate change on central banks. Bank of England Staff Working Paper, No. 603. https://www.bankofengland.co.uk.
- Bolton, P.; Després, M. ; Pereira da Silva, LA, Samama, F.; Svartzman, R. (2020). The Green Swan: Central banking and financial stability in the age of climate change, Bank for International Settlements. https://www.bis.org/publ/othp31.htm.
- Bundesbank & NGFS. (2023). NGFS Climate Scenarios for Central Banks and Supervisors, NGFS Climate Scenarios for Central Banks and Supervisors . https://www.ngfs.net.
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- National Aeronautics and Space Administration (NASA). (2024). Extreme Weather and Climate Change, https://climate.nasa.gov.
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| Stage | Main activity | Responsible or Department |
|---|---|---|
| 1. Exposure diagnosis | Portfolio mapping and risk regulation | Risk management |
| 2. Choosing scenarios | Adapting NGFS and ECB scenarios to the specifics of the bank | Climate Risk and Analysis Team |
| 3. Modeling and simulation | Assessment of the impact on capital, liquidity | Finance and modeling team |
| 4. Regulatory reporting | Communication of results to the EBA, the ECB and the public | Compliance department |
| 5.Implementation and monitoring | Development and implementation of exposure reduction plans | Top management/strategy |
| No. | Reporting component | Brief description |
|---|---|---|
| 1 | Presentation of the risk management methodology | Description of the approach and processes used to manage climate risks. |
| 2 | Portfolio analysis with exposure to climate risks | Assessing active exposure to physical and transition risks in the portfolio. |
| 3 | Results of climate stress tests on multiple scenarios | Presentation of the estimated impact under various adverse climate scenarios. |
| 4 | Details of capital and liquidity affected | Analysis of the effect of climate risks on the bank’s capital and liquidity. |
| 5 | Adjustment and adaptation plans | Proposed measures to reduce and manage the identified risks. |
| 6 | The landscape of future risks and opportunities | Identifying trends, emerging risks and opportunities generated by the climate transition. |
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