Prudential supervisors are increasingly considering how financial institutions can use their strategic transition plans to inform assessments of resilience, governance and financial stability—which, in turn, can help institutions evaluate their exposures to climate-related risks, and manage the financial implications of the transition.

While prudential supervision remains focused on safety and soundness, climate change and environmental degradation are increasingly recognized as drivers of traditional financial risks, including credit, market and operational risk. In this context, supervisors are seeking to draw on transition plans to better understand how institutions are identifying, managing and mitigating transition-related risks, with several going further by requiring transition plans to address climate-related financial risks within prudential frameworks.

This article draws on key insights from the Taskforce on Net Zero Policy’s COP30 report, Policy Matters: From Pledges to Delivery – A Decade After Paris,¹ to highlight emerging supervisory approaches and trends for financial institutions navigating evolving prudential expectations. It includes examples of how prudential supervisors in different countries and regions are approaching transition plans, and discusses implications of transition planning for banks’ risk management and governance.

Transition plans in prudential supervision: emerging supervisory perspectives

Supervisory guidance is increasingly clarifying how transition plans, as strategic documents, can be used to inform forward-looking prudential risk assessment. The 2024 Network for Greening the Financial System (NGFS) Transition Plan Package, developed by central banks and supervisors, discusses how transition plans can support risk management and microprudential supervision. Transition plans² can serve multiple purposes, including identifying and managing financial risks, explaining decarbonization strategies, supporting transition finance, and enabling alignment with the goals of the Paris Agreement.

NGFS highlights transition plans as a key input into assessing whether a bank’s risk management framework can manage risks embedded in its strategy. This underscores the need for banks to develop more integrated data systems, governance arrangements that embed climate objectives across institutions, and scenario approaches that support both strategic planning and supervisory risk assessment. As supervisory practices evolve, transition plans may also inform assessments of governance, risk appetite and business model sustainability, with potential implications for supervisory assessments and capital adequacy (Basel Framework Pillar 2) considerations.

As prudential supervisory approaches continue to evolve, discussions are beginning to broaden to consider how climate physical risk management and, consequently, climate adaptation and resilience may be reflected within transition plans. While mitigation remains central, incorporating adaptation measures over time may help strengthen institutional resilience and financial stability, and simultaneously highlight investment opportunities linked to risk reduction and preparedness.

Examples of regional and national prudential transition plans

European Union
The EU has incorporated climate and environmental risks into prudential supervision through the EU’s Capital Requirements Regulation and Capital Requirements Directive (CRRIII & CRD VI) (in effect from January 2026). The European Banking Authority (EBA) 2025 guidelines on the management of ESG risks require banks to identify and manage short- and long-term ESG risks and to monitor both backward- and forward-looking indicators, including financed emissions. Supported by the latest European Central Bank (ECB) supervisory priorities, under CRD VI article 76, banks must also produce prudential transition plans focused on risk management rather than emissions targets, distinguishing them from but connected to from those reported under the Corporate Sustainability Reporting Directive (CSRD), which requires institutions to report on the existence and key features of their transition plans, if developed.³

United Kingdom
The Prudential Regulation Authority (PRA) published a supervisory statement setting expectations for managing climate-related financial risks and clarifies how prudential principles such as proportionality, governance and forward-looking risk management apply. The PRA’s approach is aligned with the UK government policy on transition planning, emphasizing coherence between firms’ strategy, disclosures and prudential risk management, yet it does not introduce requirement to develop a transition plan.

Brazil
The Brazilian Central Bank has proposed expanding the mandatory Social, Environmental and Climate Risks and Opportunities Report (GRSAC) to align with the Basel Committee on Banking Supervision (BCBS)’s voluntary climate disclosure framework and complement International Sustainability Standards Board (ISSB) IFRS Sustainability Disclosure Standards. Expected to be adopted in 2026, the proposal strengthens and standardizes quantitative disclosures on transition and physical risks, risk management practices and voluntary commitments, while extending requirements to smaller institutions.

Looking ahead: Towards greater consistency and interoperability

Institutions that embed climate strategy within risk management frameworks are likely to be better positioned to meet evolving supervisory expectations. Prudential requirements are raising baseline expectations for transition plan quality and, in doing so, supporting system-level resilience. As supervisors make more systematic use of transition plans within their supervisory toolkits, continued progress on methodologies, reporting standards and scenario analysis will be essential to ensure these plans are decision-useful for both financial institutions and supervisory authorities.

While the value of transition plans in prudential supervision is increasingly recognized, application of these plans remains at an early stage, with differences in scope, assumptions and assurance practices limiting comparability, particularly for internationally active banks. In this context, international developments, including the BCBS voluntary framework on climate-related financial risk disclosures, can act as an important global reference point for supervisors.

Looking ahead, to maximize the decision-usefulness and comparability of transition plans across jurisdictions, supervisory practice could focus on enhanced interoperability; clearer linkages between data, methodologies and supervisory use cases; and more consistent integration of transition plans into risk management and prudential oversight. UNEP FI continues to support stakeholders in navigating this evolution through initiatives such as its Regulatory Implementation Support Programme and policy engagement through NGFS and the Taskforce on Net Zero Policy. UNEP FI has also recently published its Guide to Transition Plans for Banks and works with global standard setters to build alignment on comparability.

 

[1] UNEP FI participates in the Taskforce.
[2] The NGFS and EBA distinguish between transition planning—the internal process of developing long-term climate strategies—and transition plans, the outward-facing documents shared with regulators, investors and other stakeholders.
[3] As of the publication of this article, the final position (Omnibus simplification package) on the provisions on transition plans within CSRD has not yet been approved.

 

Sources: 
Banco Central do Brasil (2025): Public Consultation 127, Disclosure of metrics in the Social, Environmental, and Climate  
Bank of England (2025): Supervisory statement 5/25  
Basel Committee on Banking Supervision (2025): A framework for the voluntary disclosure of climate-related financial risks 
European Commission, CSRD 
European Banking Authority (2025): Final Guidelines on the management of ESG risks 
European Central Bank (2025): Supervisory priorities 2026-28 
NGFS (2025): Integrating Adaptation and Resilience into Transition plans 
NGFS (2024): Credible Transition Plans: The micro-prudential perspective 

 

Additional Resources:  
Bank of England (2025): CP10/25 – Enhancing banks’ and insurers’ approaches to managing climate-related risks 
Financial Stability Board (2025): The Relevance of Transition Plans for Financial Stability 
Dikau et al. (2024): Prudential net zero transition plans: the potential of a new regulatory instrument 
Grantham Research Institute (2022): Net zero transition plans: a supervisory playbook for prudential authorities 
NGFS (2025): Interactions between climate scenario analysis and Transition plans 
NGS (2025):Target setting and Transition plans 
NGFS (2023): Stocktake on Financial Institutions’ Transition Plans and their Relevance to Micro-prudential Authorities 
UNEP FI (2025): Guide to Transition Plans for Bank 
UNEP FI (2021): Good Practice Guide to Climate Stress Testing