NVB responds to ECB consultation on its Guide on climate-related and environmental risks

The Dutch Banking Association welcomes the possibility to respond to the ECB consultation and agrees with the ECB that climate-related and environmental risks should be management carefully within the current prudential framework. This is what the NVB states in its response to the consultation on the draft Guide of the ECB on climate-related and environmental risks. The Guide needs further clarification and elaboration on a few matters, according to the NVB. The NVB states that the proposed timelines with regard the expectations are ambitious, and hence invites, the ECB for a phasing-in approach of the guide’s expectations. The NVB requests the ECB to clarify on the application and proportionality of the Guide. Also, the NVB emphasises its concern on the lack of (historic) data with regard to climate and environmental risks. Lastly, the NVB asks the ECB to clarify on the definition and positioning of climate risk, in relation to other environmental risks, to avoid misunderstanding and possible double counting of risk.