DNB publiceert aanpak voor de beheersing van klimaat- en milieurisico’s voor financiële-marktinfrastructuren

The DNB has released a set of good practices aimed at helping FMIs manage climate and environmental risks. These good practices are non-binding guidelines for FMIs, including central counterparties, central securities depositories, payment systems, and securities settlement systems, to organize their processes and procedures to address climate and environmental risks. The goal is to provide a basis for discussions within the FMI ecosystem and to facilitate supervisory dialogue between Dutch FMIs and DNB.
The good practices for FMIs were developed based on the Bank for International Settlements PFMI. They were created after consulting with Dutch FMIs and representatives from the Dutch FMI ecosystem. The DNB had previously published the DNB Guide on managing climate and environmental risks, which primarily focused on entities like insurers, pension funds, investment firms, and electronic money institutions, please also note EventID#22374. These new good practices specifically target FMIs and aim to fill a gap in guidance from the perspective of DNB, which serves as the supervisory authority for FMIs and seeks to promote sound risk management within the sector.
The importance of managing climate and environmental risks lies in the potential financial and non-financial risks that FMIs may face due to climate change and environmental degradation. These risks can result from both physical impacts and transition factors, leading to risks such as market and reputational risks. The extent of these risks may vary among sectors and depends on the specific business models of FMIs.
FMIs have the flexibility to take different approaches as long as they comply with applicable laws and regulations.
DNB also encourages FMIs to proactively address climate and environmental risks and contribute to the transition to a sustainable economy through innovative products and services while reducing their own environmental footprint.
To help FMIs manage climate and environmental risks, DNB offers non-binding guidance, focusing on three pillars of engagement. The first pillar involves integrating these risks into risk management practices. The second pillar encourages FMIs to contribute to the transition to net zero emissions by 2050 through innovation of products and services. The third pillar involves examining an FMI’s own environmental footprint.
While the existing EU legislation applicable to FMIs follows PFMI, it doesn’t explicitly address climate and environmental risks. These good practices aim to provide guidance on how FMIs can apply PFMI principles to manage climate and environmental risks. FMIs are encouraged to consider the materiality and proportionality of these risks to their business.
The guide also highlights key points for conducting a materiality analysis of climate and environmental risks, such as differentiating between physical and transition risk factors, assessing their impact on various risk areas, considering different time horizons, using both qualitative and quantitative analysis methods, and conducting a materiality assessment tailored to the FMI’s business model and risk profile.
The document includes practical examples of how climate and environmental risks can be integrated into areas like governance, risk management, and disclosure, which FMIs can adapt to their specific circumstances.