2021 Country Progress Report Pakistan

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Pakistan

Country Progress Report


April 2022

SUPPLEMENT TO THE 2021 GLOBAL PROGRESS REPORT OF


THE SUSTAINABLE BANKING AND FINANCE NETWORK
Acknowledgements
This Country Progress Report was developed by the SBFN Secretariat under the leadership of the SBFN
Measurement Working Group and with guidance from the SBFN Pakistan Country Coordinator, Afifa Raihana
and Asia Regional Coordinator, Wei Yuan. Data are provided by the State Bank of Pakistan (SBP) and verified by
SBFN. The team is grateful for the support and guidance of SBP representatives who provided data, participated in
interviews, and reviewed and provided comments to this report, in particular Zarak Khan, Assistant Director and
Muhammad Irfan Saleem, Assistant Director of Green Banking Division – Infrastructure, Housing & SME Finance
Department (IH&SMEFD).

About SBFN About IFC

Established in 2012, SBFN is a voluntary community of IFC—a member of the World Bank Group—is the largest
financial sector regulators and industry associations from global development institution focused on the private
emerging markets committed to collectively advancing sector in emerging markets. IFC works in more than 100
sustainable finance in line with international good practice countries, using its capital, expertise, and influence to
and national priorities. As of October 2021, SBFN members create markets and opportunities in developing countries.
represented 63 institutions, 43 countries, and $43 trillion (86 In fiscal year 2021, IFC committed a record $31.5 billion to
percent) of the total banking assets in emerging markets. private companies and financial institutions in developing
Members are committed to i) improving the management of countries, leveraging the power of the private sector to
environmental, social, governance, and climate change risks end extreme poverty and boost shared prosperity as
in financial sector activities, and ii) increasing capital flows economies grapple with the impacts of the COVID-19
to activities with positive environmental and social impacts, pandemic. For more information, visit www.ifc.org.
including climate change mitigation and adaptation. For
more information, visit www.sbfnetwork.org.

© International Finance Corporation [2022], as the Secretariat of the Sustainable Banking and Finance Network (SBFN). All
rights reserved. 2121 Pennsylvania Avenue, N.W. Washington, D.C. 20433 Internet: www.ifc.org. The material in this work is
copyrighted. Copying and/or transmitting portions or all of this work without permission may be a violation of applicable
law. IFC and SBFN encourage dissemination of their work and will normally grant permission to reproduce portions of the
work promptly, and when the reproduction is for educational and non-commercial purposes, without a fee, subject to such
attributions and notices as we may reasonably require.

IFC and SBFN do not guarantee the accuracy, reliability, or completeness of the content included in this work, or the
conclusions or judgments described herein, and accept no responsibility or liability for any omissions or errors (including,
without limitation, typographical errors and technical errors) in the content whatsoever or for reliance thereon. The boundaries,
colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The
World Bank Group concerning the legal status of any territory or the endorsement or acceptance of such boundaries.

This work was prepared in consultation with SBFN members. The findings, interpretations, and conclusions expressed
in this volume do not necessarily reflect the views of the Executive Directors of The World Bank Group, IFC, or the
governments they represent. The contents of this work are intended for general informational purposes only and are not
intended to constitute legal, securities, or investment advice, an opinion regarding the appropriateness of any investment,
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Contents

1 2
Overall country progress
– Pakistan Progress by three pillars
1. SBFN member institutions Pillar 1: ESG Integration
2. Other key institutions and Pillar 2: Climate Risk Management
national initiatives promoting Pillar 3: Financing Sustainability
sustainable finance
3. Overall progress page 6

4. Country sustainable finance


journey
5. COVID response
6. Ambitions for the next phase
7. SBFN and IFC role

page 2

3 4
Progress by three sub-pillars Library of national
and 11 indicators sustainable finance
framework documents
Sub-pillar 1: Strategic Alignment
Sub-pillar 2: Regulatory and Industry National strategies, roadmaps,
Association Actions policies, voluntary principles,
regulations, guidelines, research,
Sub-pillar 3: Expectations of Financial
templates, and tools that provide
Institution Actions
an enabling framework for
page 11 sustainable finance

page 12

5
SBFN measurement
framework
and methodology
Summary of the SBFN measurement
framework, a systematic approach
to benchmark country progress in
developing national enabling frameworks
for sustainable finance

page 13

Note to the reader: All measurement results featured in this document, such as graphs and progression matrixes, are based on data collected up
to July 2021. Additional activities up to the publishing date of this country report have been included in narrative form.

1
1. Overall country progress – Pakistan
1.1 SBFN member institution:

State Bank of Pakistan (SBP) Member Since: 2015 Working Groups:


International Development
Association Task Force

1.2 Other key institutions and national initiatives promoting sustainable finance

Government of Pakistan Pakistan Banks’ Association (PBA)


Collaboration with Green Climate Fund through the National Institute of Banking & Finance (NIBAF)
Deutsche Gesellschaft fur Internationale Clean Green Pakistan Movement (GoP), 2018
Zusammenarbeit (GIZ) Ten Billion Tree Tsunami Program (GoP), 2018

1.3 Overall progress

Pakistan has continued to make progress in the “Developing” sub-stage of the “Implementation” stage of the SBFN
Progression Matrix. It has formally launched its sustainable finance framework, including the State Bank of Pakistan (SPB)
Green Banking Guidelines (2017). The Securities and Exchange Commission of Pakistan issued the Green Bond Guidelines
in 2021. The SBP monitors the implementation of the sustainable finance framework, and provides regulatory guidance to
enhance knowledge and capacity of financial institutions on ESG and climate risk management. The Green Bonds Guidelines
provide a framework and guidance to promote sustainable investment flows. Awareness raising and capacity building have
been conducted.

2
Figure 1: SBFN Progression Matrix - Overall Country Progress
Overall Results (without movements)
Maturing
Implementation
Mainstreaming
Preparation Consolidating
Behavioral Changes
Developing Advancing
Commitment Formulating China
Argentina Bangladesh
Colombia
Cambodia Brazil
Kazakhstan Indonesia
Chile
Costa Rica Georgia
Lao PDR Fiji
Dominican Kenya
Maldives Jordan Republic
Mexico
Samoa Kyrgyz Ecuador
Republlic Mongolia
Serbia Egypt
Morocco
Tunisia Ghana
Nigeria
Honduras
South
India Africa

Iraq Turkey

Nepal Vietnam

Pakistan

Panama

Paraguay

Peru

Philippines

Sri Lanka

Thailand

Ukraine * Countries within each sub-stage are listed in alphabetical order

1.4 Country sustainable finance journey

Figure 2: Pakistan’s sustainable finance journey

Research and engagement Examples of


Policies, principles, regulations,
(since last SBFN progress market actions
and guidance.
report) and impacts

2012- 2015-
2009 2013 2016

SBP launches Scheme for Ministry of Climate Change State Bank of Pakistan
Financing Power Plants issues the National Climate joins SBFN
Using Renewable Energy Change Policy
SBP issues Revised
5
Securities and Exchange Financing Scheme for
Commission of Pakistan Renewable Energy
issues the Corporate
Social Responsibility (CSR) Government of
Voluntary Guidelines Pakistan sets the
Nationally Determined
Contributions to achieve
the targets set out in the
3
Paris Agreement
2018 2017

SBP issues the Guidelines on Environmental SBP issues the Green Banking Guidelines
and Social Risk Management (ESRM) Policy and
Procedures for Microfinance Banks (MFBs), Non-Bank The Government of Pakistan & UNDP publish the
Microfinance Companies and Non-Bank Finance Pakistan Climate Change Financing Framework: A Road
Companies in Pakistan Map to Systemically Mainstream Climate Change into
Public Economic and Financial Management
SBP quarterly seeks implementation status of the
Green Banking Guidelines from more than 30 banks
and Development Financial Institutions (DFIs)

SBP arranges workshops and training sessions for the


banking industry to build awareness and capacity for
green banking

Government of Pakistan launches Clean Green


Pakistan Movement (CGPM)

Government of Pakistan launches Ten Billion Trees


Tsunami Program

2020-
2019 2022
2021
Government of Pakistan issues Government of Pakistan SBP launches the SDGs and
Alternative and Renewable Energy launches Protected Area Sustainability Report – Pakistan
Policy (ARE Policy) Initiative (PAI) Banking Sector Perspective,
mapping the progress of
Government of Pakistan and WWF Government of Pakistan issued Pakistan’s banks towards the
jointly launch Recharge Pakistan: Electric Vehicle Policy 2020- Sustainable Development Goals
Building Pakistan’s Resilience to 2025 (Draft) (SDGs) and identifying specific
Climate Change through Ecosystem- gaps
Based Adaptation for Integrated Flood As of June, 2021, Financing
Risk Management Scheme for Renewable Energy
has financed approximately 717
SBP enhances the scope of the projects, with a total capacity
Refinancing Facility for Modernization of 1,082 megawatts and total
of Small and Medium Enterprises outstanding loans of 53 billion
(SMEs) by including new zig-zag Pakistani rupees
technology brick kilns for financing
under the scheme Securities and Exchange
Commission of Pakistan
SBP further revises and extends the (SECP) issues the Green Bonds
Financing Scheme for Renewable Guidelines
Energy to June 2022

4
1.5 COVID response

On 30 March 2020, the Government of Pakistan approved a fiscal stimulus package of 1.2 trillion Pakistani rupees ($8 billion)
and a supplementary grant of 100 billion Pakistani rupees for the Residual/Emergency Relief Fund to mitigate the effects
of COVID-19. Furthermore, SBP announced the Temporary Economic Refinance Facility amounting to 436 billion Pakistani
rupees to stimulate investment in the manufacturing sector. Several other measures have also been implemented, such as
the refinance scheme for payment of wages and salaries (Rozgar Scheme), the Refinance Facility for Combating COVID-19
(RFCC) to enhance the capacity of health sector, the deferment of monthly and quarterly fuel adjustments in electricity bills,
power tariff freezing, an incentive package for the construction industry, and a series of loan repayment deferments.

1.6 Ambitions for the next phase

The SBP is currently focusing on implementing the Green Banking Guidelines, published in 2017. To this end, SBP has
initiated a project with IFC namely, called the Pakistan Sustainable Banking Project. The project will focus on developing
implementation tools to support the effective uptake of the guidelines by banks on environmental and social risk
management, raising awareness and building capacity of the entire banking industry, and creating market capacity
for local training intermediaries. In addition, defining green or sustainable projects in Pakistan is also under SBP’s
consideration in the form of Green Taxonomy. Other future initiatives include assessing the market readiness for green
bonds, and preparing a manual for green business facilitation for financial institutions.

1.7 SBFN and IFC role

IFC has provided advisory services to the SBP for their sustainable finance initiatives and capacity building, in partnership
with the Government of Pakistan.

5
2. Progress by three pillars
Figure 3: Mapping of overall country progress and individual pillar progress

Overall mapping

Maturing
Implementation
Preparation Consolidating Mainstreaming
Behavioral Changes
Developing Advancing
Commitment Formulating

Pillar-level mapping

Pillar 2: Pillar 3: Pillar 1:


Climate Risk Financing ESG
Management Sustainability Integration

1. Progress by 3 Pillars
Pillar 1: ESG Integration
Pillar 1: ESG Integration
Pillar Progress: Advancing

Pakistan is mapped under the “Advancing” sub-stage of the “Implementation” stage for the ESG Integration Pillar.
There is an existing national framework addressing the integration of ESG risk and performance considerations into the
practices of financial institutions. In addition to ongoing activities to raise awareness and build capacity, implementation
tools and initiatives are in place, and financial institutions (FIs) report on their ESG implementation with consistent reporting
instructions or templates.

Strategic Alignment

Pakistan

South Asia

SBFN Average

Expectations of Financial Regulatory and Industry


Institution (FI) Actions Association Actions

Sub-pillar 1: Strategic Alignment parallel to other guidelines such as the Code of Corporate
• Pakistan’s national framework for the banking Governance and Corporate Social Responsibility
sector and non-banking sector, including the Green Voluntary Guidelines issued by the Securities and
Banking Guidelines (SBP, 2017), sets out expectations Exchange Commission of Pakistan in 2013.
for integrating the consideration of ESG risks and • The Pakistani financial sector’s approach to ESG
performance. The Green Banking Guidelines run in integration is in alignment with international good

6
practices and standards, such as the UN Sustainable Sub-pillar 3: Expectations for FI Actions
Development Goals. • The Green Banking Guidelines require FIs to develop
• The Green Banking Guidelines framework was developed policies and procedures to manage ESG risks and
and/or implemented in close consultation with performance, undertake regular review and monitoring of
stakeholders. ESG risks, and report ESG performance to SBP.

Sub-pillar 2: Regulatory and Industry Association Actions


• Pakistan’s sustainable finance framework is supported
with implementation guidance and technical tools in
the Green Banking Guidelines. The Guidelines provide
instructions on environmental due diligence and
environmental risk characterization and rating.
• The implementation of the framework is regularly
monitored by SBP. SBP is formulating regulatory
guidance to enhance knowledge and capacity of banks
on environmental and social risk management (ESRM)
and integrating climate change and other sustainability
concerns into their risk management systems.

7
Pillar 2: Climate Risk Management
Pillar Progress: Formulating

Pillaris2:
Pakistan Climate
in the RiskSub-stage
“Formulating” Management
of the “Preparation” Stage of the Climate Risk Management Pillar. SBP’s
Green Banking Guidelines highlight the country’s vulnerability to climate risks and incorporate climate risk considerations as
part of environmental risk in the overall ESG approach to risk management, and provide a foundation for the incorporation
of more comprehensive approaches to manage climate-related physical and transition risks and financial impacts.
Preparations and activities include research, surveys, and/or multi-stakeholder engagement and awareness raising on
expectations for climate risk management.

Strategic Alignment

Pakistan

South Asia

SBFN Average

Expectations of Financial Regulatory and Industry


Institution (FI) Actions Association Actions

Sub-pillar 1: Strategic Alignment risk management procedures and overall credit risk
• Addressing climate change risks is a national priority as management on a transaction and portfolio basis.
indicated in Pakistan’s Intended Nationally Determined • In 2019, the Government of Pakistan and WWF jointly
Contribution (INDC) to the Paris Agreement and its launched Recharge Pakistan: Building Pakistan’s
national climate policies, including the National Climate Resilience to Climate Change through Ecosystem-Based
Change Policy for Pakistan. In the financial sector, the Adaptation for Integrated Flood Risk Management.
SBP’s Green Banking Guidelines incorporate climate risk • In 2020, Pakistan’s government launched the Protected
considerations as part of environmental risk in the overall Area Initiative, which aims to increase protected areas
ESG approach for risk management. such as national parks, wetlands, and wildlife reserves to
15 per cent of the country’s total area by 2023.
Sub-pillar 2: Regulatory and Industry Association Actions • As part of future SBP capacity-building efforts on climate
• SBP’s Green Banking Guidelines (2017) highlight the risk, recommended areas of focus by SBP for regulatory
country’s vulnerability to climate risks and the importance and industry association actions include research,
of a transition to a low-carbon and climate-resilient capacity building, technical guidance (such as climate
economy. The Guidelines provide a foundational scenarios and risk assessment methodologies), and further
framework for environmental and social (E&S) risk development of regulatory and supervisory expectations
management in the banking sector and include specific for FIs for managing climate-related physical and transition
reference to climate change risks as part of E&S risks and financial impacts.

2
Sub-pillar 3: Expectations for FI Actions as well as future financing; and investments of banks in
• Application of the Green Banking Guidelines serves to credit and operational risk management procedures. The
build familiarity and capacity among Pakistani financial Guidelines describe how risks from climate change may
institutions to improve climate risk management practices affect a bank’s balance sheet if a client’s activities and
as part of overall ESG risk management approaches. assets are impacted and result in reduced cash-flow and
The Guidelines’ E&S risk management approach is impairment of loan repayment capability.
designed to incorporate procedures for evaluation and • In 2021, with the support of IFC and the World Bank and
management of environmental and climate change risks in collaboration with the Pakistan Banking Association,
and related financial impacts; these include physical risks SBP will lead the development of regulatory guidance,
like flooding and drought in sectors such as agriculture training and capacity building, and implementation
and manufacturing; risks related to a low-carbon tools to support the further integration of the Green
transition, such as technology changes and market Banking Guidelines into the risk management of financial
preference shifts to renewable sources of fuels of current institutions, with an initial focus on E&S risk management.

9
Pillar 3: Financing Sustainability
Pillar Progress: Developing

Pillar
Pakistan3:
is inFinancing Sustainability
the “Developing” sub-stage of the “Implementation” stage for the Financing Sustainability Pillar. There is a
national framework for promoting financial flows into green, climate, social, and sustainability-linked projects and sectors, and
ongoing awareness raising and capacity building on financing sustainability actions and expectations. In 2021, the Securities
and Exchange Commission of Pakistan issued the Green Bonds Guidelines for the corporate sector to raise funds from the
capital market to finance or refinance projects that contribute positively to the environment.

Strategic Alignment

Pakistan

South Asia

SBFN Average

Expectations of Financial Regulatory and Industry


Institution (FI) Actions Association Actions

Sub-pillar 1: Strategic Alignment • The framework also tasks SBP to monitor the progress of
• Pakistan’s national framework for financing sustainability, implementation of the national framework on financing
led by SBP’s Green Banking Guidelines (2017) and the sustainability on a regular basis.
Securities and Exchange Commission of Pakistan’s Green • In 2019, SBP enhanced the scope of the Refinancing
Bond Guidelines (2021), covers both the banking sector and Facility for Modernization of Small and Medium
the capital markets. Enterprises (SMEs) by including new zig-zag technology
• The Pakistani financial sector’s approach to financing brick kilns for financing under the scheme.
sustainability encourages cooperation between agencies
or between the regulator and industry associations with Sub-pillar 3: Expectations for FI Actions
respect to policy design or implementation related to • Pakistan did not report specific policies or actions related
sustainable finance flows. It highlights the importance of to expectations for FI actions in this cycle. The SBP is
building conducive relationships with the government expected to develop standard ESG reporting procedures
agencies entrusted with implementation of environmental and contents, which will impose expectations for
regulations. reporting on FIs.
• Pakistan’s Green Bonds Guidelines ask issuers to publish
Sub-pillar 2: Regulatory and Industry Association Actions annual updates on the performance and impacts, obtain
• Pakistan’s Green Banking Guidelines provide examples and disclose independent reviews, and publish such
of opportunities for financing environmentally friendly information on their websites. The information includes
activities in almost all sectors and for almost all sizes of performance indicators (qualitative and quantitative)
businesses and households. The Green Bonds Guidelines showing expected environmental and social impact of
provide technical details on issuance of green bonds, the projects that have received funding.
use of proceeds, and external reviewers.

10
For details for each pillar, sub-pillar, indicator, datapoint, and referring policy document, please visit the SBN Online Analytical Tool at [URL TBD].

3
2. Progress by 3 Sub-Pillars and 11 Indicators
3. Progress by three sub-pillars and 11 indicators
Figure4:
Figure 1: Overviewof
Overview ofPakistan’s
Pakistan’ssustainable
sustainablefinance
financecoverage
coveragein
inthree
threeframework
thematic areas
areas

Pillar 1: Pillar 2: Pillar 3:


ESG Integration Climate Risk Management Financing Sustainability
Sub-pillar 1: Strategic Alignment

National Framework Coverage

Alignment with International


Goals & Standards

Alignment with National Goals


& Strategies

Sub-pillar 2: Regulatory and Industry Association Actions

Overall Approach & Strategy

Technical Guidance

Supervisory Activities &


Incentives

Tracking & Aggregated


Disclosure

Sub-pillar 3: Expectations of Financial Institution (FI) Actions

Strategy & Governance

Organizational Structure &


Capacity Building

Policies & Procedures

Tracking, Reporting & Disclosure

All data in the report are pending member confirmation. 4

11
4. Library of national sustainable finance
framework documents
National strategies, roadmaps, policies, voluntary principles, regulations, guidelines,
research, templates, and tools that provide an enabling framework for sustainable finance

Green Bonds Refinancing Facility Alternative and Renewable


Guidelines for Modernization of Energy Policy (ARE Policy)
Small and Medium
(SECP, 2021) (Government of Pakistan, 2019)
Enterprises
(SBP, 2019)

Revised Financing Guidelines on Environmental and Social Risk Management


Scheme for Renewable (ESRM) Policy and Procedures for Microfinance Banks
Energy (MFBs), Non-Bank Microfinance Companies and Non-Bank
Finance Companies in Pakistan
(SBP, 2019)
(SBP, 2018)

Green Pakistan-Climate Change Financing Financing


Banking Framework: A Road Map to Systemically Scheme for
Guidelines Mainstream Climate Change into Public Renewable
(SBP, 2017) Economic and Financial Management Energy
(Government of Pakistan & UNDP, 2017) (SBP, 2016)

Download framework documents and check for updates at www.sbfnetwork.org/library

12
5. SBFN measurement framework
and methodology
About SBFN An evolving framework
Established in 2012, the Sustainable Banking and Finance The SBFN Measurement Framework reflects the activities,
Network (SBFN) is a unique, voluntary community strategies, and tools that members use to promote
of financial sector regulatory agencies and industry sustainable finance in their countries. It evolves to match
associations from emerging markets committed to advances in country initiatives. It also incorporates the latest
advancing sustainable finance in line with international international standards and best practices identified by
best practice. SBFN is facilitated by IFC as secretariat, and members as important to their efforts.
supported by the World Bank Group.
A member-led approach
As of October 2021, SBFN comprised 43 member countries The Framework was designed with extensive member input
representing over US$43 trillion and 86 percent of total under the leadership of the Measurement Working Group
banking assets in emerging markets. Members are and Co-Chairs. Updates to the Framework are guided by
committed to collectively driving measurable change. the Measurement Working Group and agreed by all SBFN
Members.
Why a measurement framework?
In 2016, members requested a systematic comparison of Data collection in partnership with members
country approaches to developing national sustainable As of 2021, data collection for the SBFN Global Progress
finance frameworks. The SBFN Measurement Working Report relies on member country reporting in line with the
Group was established to convene member inputs on the updated Measurement Framework. Information is supported
design of a common framework to benchmark country by evidence, which is verified by the SBFN secretariat in
progress and accelerate peer-to-peer knowledge exchange. collaboration with third-party service providers. Evaluation
The Framework is designed to inform the biennial SBFN and milestones are objective and transparent. Members
Global Progress Report. approve the final Global and Country Progress Reports.

The Framework can be used as: The Measurement Framework is based on three
intersecting themes in sustainable finance. For each
a mapping tool to capture the dynamic theme, it assesses regulatory guidance, supervision
interaction of collective insights, market- strategies, disclosure requirements, and voluntary
based actions, and policy leadership industry approaches.
demonstrated by SBFN members as they
move their financial markets ESG Integration refers to the management of
toward sustainability; environmental, social, and governance (ESG) risks in
the governance, operations, lending, and investment
a benchmarking tool for SBFN activities of financial institutions.
members to learn from and compare
peer approaches, track and review Climate Risk Management refers to new governance,
progress against global benchmarks, risk management, and disclosure practices that financial
develop common concepts and institutions can use to mitigate and adapt to climate change.
definitions, and leverage innovations
and strengths; and Financing Sustainability refers to initiatives by
regulators and financial institutions to unlock capital flows
a forward planning and capacity for activities that support climate, green economy, and
building tool to identify future policy social goals. This includes new products like green bonds
pathways and capacity building needs. and sustainability-linked loans. Initiatives include definitions,
guidance, taxonomies, monitoring, and incentives.

13

1
The Measurement Framework consists of three complementary
components:

1. Progression matrices
The stage mapping is based on qualitative milestones and
Drawing on SBFN members’ common development paths quantitative analysis related to (i) progress in developing
and milestones, the SBFN Progression Matrix provides and implementing national policies and principles, and (ii)
an overview of market-wide progress for all SBFN countries industry uptake and practices. In the 2021 report, in addition
across three typical stages of development. It allows each to the Overall Progression Matrix, three pillar-level matrices
SBFN member to review its own progress and identify the are added to reflect a country’s development process in
strengths and weaknesses of its approach. each of the pillar areas.

Overall Mapping Country

Maturing
Implementation
Preparation Consolidating
Mainstreaming
Behavioral Changes
Developing Advancing
Commitment Formulating

Pillar-Level Mapping

Pillar 2: Pillar 3: Pillar 1:


Climate Risk Financing ESG
Management Sustainability Integration

2. Pillar benchmarking

A dynamic assessment is conducted Pillar 1: Pillar 2: Pillar 3:


Climate Risk Financing
across several priority pillars of sustainable ESG Integration Management Sustainability
finance, using qualitative and quantitative
• National framework
datapoints to assess progress and allow Sub-pillar 1:
• Alignment with international goals and standards
comparison across countries. Three pillars, Strategic Alignment • Alignment with national goals and strategies

three cross-cutting sub-pillars, 11 cross-


Sub-pillar 2: Regulatory • Overall approach and strategy
cutting indicators, and 75 underlying • Technical guidance
and Industry Association • Supervisory activities and incentives
datapoints are used to objectively assess a Actions • Tracking and aggregated disclosure
country’s sustainable finance framework(s),
Sub-pillar 3: • Strategy and governance
according to clarity, depth, and alignment • Organizational structure and capacity
Expectations of Financial • Policies and procedures
to international good practice. Institution (FI) Actions • Tracking, reporting, and disclosure

3. Sector data and case studies

In 2021, data collection included an exploratory request for quantitative data points — where available — for the number and
percentage of financial institutions that are implementing ESG integration as well as climate risk management and disclosure;
and the total value of green, social, and sustainability bond issuance. Detailed case studies were also collected of innovative
approaches by regulators and industry. Case studies will be published in a new on-line case study catalogue.

SBFN on-line case study catalogue


Coming soon

14
SBFN Measurement Framework pillars, sub-pillars, indicators, and underlying datapoints
Pillar 1: ESG Integration
Sub-
Indicator No. Underlying datapoint
pillar
National framework1 1 Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for
(e.g. policies, roadmaps, integrating the consideration of environmental, social, and governance (ESG) risks and performance?
guidance, regulations, 2 Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs
voluntary principles, that sets out expectations for integrating the consideration of ESG risks and performance?
Strategic Alignment

templates, or tools)
Alignment with 3 Does the Framework make reference to international sustainable development frameworks or goals?
international goals and
standards
4 Does the Framework make reference to established international ESG risk management standards and principles for FIs?

Alignment with national 5 Does the Framework make reference to specific national development objectives, plans, policies, goals, or targets?
goals and strategies 6 Does any cooperation exist between agencies or between the regulator and industry association with respect to policy design and/or
implementation related to ESG integration?
7 Does any inter-agency data sharing currently exist related to ESG integration by FIs?
Overall approach and 8 Does the Framework provide guidance on the role of the regulator or industry association with regard to assessing and managing ESG risk
Regulatory and Industry Association Actions

strategy and performance in the financial sector?


9 Has the regulator or industry association undertaken market assessment to identify systemic ESG risks through analysis of the portfolios of
supervised entities/members and published the results?
Technical guidance 10 Does the Framework provide technical guidance or tools to support implementation of ESG risk and performance management by the
financial sector?
Supervision activities 11 Is the implementation of the Framework regularly monitored and/or information regularly collected from FIs by the regulator and/or industry
and incentives association?
12 Does the regulator or industry association provide any financial or non-financial incentives for FIs to manage ESG performance as part of the
Framework?
13 Does the regulator or industry association apply any disincentives/penalties for non-compliance by FIs in terms of expectations from the
regulator and/or industry association related to ESG risk management as part of the Framework?
Tracking and 14 Has the regulator or industry association established a data collection approach and database to track or regularly publish data related to
aggregated disclosure ESG integration by FIs as part of the Framework?
Strategy and 15 Does the Framework require/ask the FI’s board of directors (or highest governing body) to approve an ESRM and/or ESG integration strategy,
governance and to supervise its implementation?
Organizational structure 16 Does the Framework require/ask FIs to allocate resources/budget commensurate with portfolio ESG risks and define roles and
and capacity responsibilities for ESG integration within the organization?
17 Does the Framework require/ask FIs to develop and maintain the ESG expertise and capacity of staff commensurate with portfolio ESG risks
Expectations of FI Actions

through regular training and learning?


18 Does the Framework require/ask FIs to create incentives for managers to reduce the ESG risk-level of the portfolio over a specified
timeframe?
Policies and procedures 19 Does the Framework require/ask FIs to develop policies and procedures to identify, classify, measure, monitor, and manage ESG risks and
performance throughout the financing cycle at the client level and/or the transaction/project level?
20 Does the Framework require/ask FIs to undertake a regular review and monitoring of ESG risk exposure at aggregate portfolio level?
21 Does the Framework require/ask FIs to establish and maintain an external inquiry/complaints/grievance mechanism for interested and
affected stakeholders in relation to ESG practices?
Tracking, reporting, and 22 Does the Framework require/ask FIs to report ESG risks and performance to the regulator or industry association?
disclosure 23 Does the Framework require/ask FIs to report on ESG integration publicly?
24 Does the Framework require/ask FIs to track credit risk (e.g. loan defaults) and/or financial returns in relation to ESG risk level?

Pillar 2: Climate Risk Management


National framework 25 Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for
integrating the consideration and management of climate risks and their impact in the national economy?
26 Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance, or other non-lending FIs
that sets out expectations for integrating the consideration and management of climate risks and their impact in the national economy?
Strategic Alignment

Alignment with 27 Does the Framework make reference to international agreements or frameworks to address climate?
international goals and
28 Does the Framework recognize or align with established regional or international good practice for climate risk management and disclosure
standards
by FIs?
Alignment with national 29 Has the regulator or industry association aligned the Framework with national goals to address climate change in line with the country’s
goals and strategies Nationally Determined Contributions (NDCs) to the Paris Agreement?
30 Does any cooperation exist between agencies, or between government and industry association, with respect to policy design or
implementation related to climate risk management?
31 Does any inter-agency data sharing currently exist related to climate risk management by FIs?

1 National framework refers to the collective set of policies, roadmaps, guidance, regulations, and/or voluntary principles issued by national regulators or industry associations in
relation to each pillar of sustainable finance. SBFN recognizes that national frameworks for sustainable finance vary from country to country and are influenced by national priorities
and characteristics. They are also often interdependent with other national roadmaps, policies, and regulations. Countries vary in their starting points and the types of documents
to kickstart the enabling framework. For instance, initial frameworks could choose to focus on ESG risk management and/or sustainable finance opportunities such as green bonds.
They could also focus on banking, capital markets, or institutional investors. The variety of SBFN frameworks provides a rich source of inspiration for peer learning and collaboration.

15
3
Overall approach and 32 Has the regulator or industry association undertaken research on historical impacts to the economy and financial sector from climate
strategy change, and/or future expected impacts resulting from physical and transition climate risks?
Regulatory and Industry
Association Actions

33 Does the Framework identify key sources of GHG emissions – such as in particular sectors – as priorities in the proactive management of
climate risks by the financial sector?
34 Does the Framework incorporate the conservation/restoration of natural carbon sinks (such as oceans, forests, mangroves, grasslands, and
soils) as an important part of reducing climate change risks (e.g., through guidelines, scenario analysis, targets, or incentives for FIs)?
35 Has the regulator or industry association developed an internal strategy to address climate risk, and/or embedded climate risk management
into its governance, organizational structures, and budget as part of the Framework?
36 Has the regulator or industry association undertaken any activities to expand and deepen analytical understanding of national and/or cross-
border physical and transition climate risks, and to raise awareness as to how these risks may transmit to, and impact, the financial sector?
Technical guidance 37 Has the regulator or industry association developed risk assessment approaches, methodologies, or tools to understand and assess the
financial sector’s exposure to climate risk as part of the Framework?
Regulatory and Industry

Supervisory activities 38 As part of the Framework, has the regulator clarified supervisory expectations with regard to climate risk management by FIs, including
Association Actions

and incentives consideration of international good practices?


39 Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework?
40 Is the implementation of the Framework regularly monitored and/or information regularly collected from FIs by the regulator and/or industry
association?
41 Are there any financial or non-financial incentives to encourage FIs to establish climate risk management systems?
Tracking and aggregated 42 Does the regulator or industry association regularly collect and/or report market-level and/or FI-level data on climate-related financial sector
disclosure risks as part of the Framework?
Strategy and governance 43 Does the Framework require/ask FIs to establish a strategy for climate risk management with responsibility at the board of director level (or
highest governing body)?
Organizational structure 44 Does the Framework require/ask FIs to define the roles and responsibilities and related capacities of the FI’s senior management and
and capacity operational staff in identifying, assessing, and managing climate-related financial risks and opportunities?
Expectations of FI Actions

Policies and procedures 45 Does the Framework require/ask FIs to expand existing risk management processes to identify, measure, monitor, and manage/mitigate
financial risks from climate change?
Tracking, reporting, and 46 Does the Framework require/ask FIs to report on their overall approaches to climate risk management in line with international good
disclosure practices (e.g. TCFD), or establish a timeline by which FIs should begin to align their reporting with such practices?
47 Does the Framework require/ask FIs to identify, measure, and report on exposure to sectors which are vulnerable to transition risk and
physical risk?
48 Does the Framework require/ask FIs to adopt and report on performance targets to reduce portfolio greenhouse gas (GHG) emissions on a
regular basis?
49 Does the Framework require/ask FIs to adopt and report on performance targets to reduce exposure to climate change risks at the portfolio
level on a regular basis?

Pillar 3: Financing Sustainability


National framework 50 Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for
integrating the consideration of instruments, goals, and standards for financing sustainability, including requirements for ensuring credibility
and managing and measuring resulting impacts in the national economy?
51 Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance, or other non-lending
FIs that sets out expectations for integrating the consideration of instruments, goals, and standards for financing sustainability, including
requirements for ensuring credibility and managing and measuring resulting impacts in the national economy?
Strategic Alignment

Alignment with 52 Has the regulator or industry association developed a strategy, regulations, or set of frameworks for stimulating the allocation of capital to
international goals and sustainable assets, projects, and related sectors in line with global goals, such as the Sustainable Development Goals (SDGs)?
standards 53 Does the Framework recognize and/or align with existing standards, voluntary principles, or market good practices related to sustainable
finance instruments?
Alignment with national 54 Does the Framework enable the achievement of stated national objectives by guiding capital to sectors, assets, and projects that have
goals and strategies environmental and social benefits in line with national sustainable development priorities, strategies, targets, and the size of sustainable
investment needs, and taking into account the local barriers to scaling-up sustainable finance?
55 Does any cooperation exist between agencies or between the regulator and industry association with respect to policy design or
implementation related to sustainable finance flows?
56 Does any inter-agency data sharing currently exist related to stimulating and monitoring sustainable finance flows?
Overall approach and 57 Does the Framework require/ask the regulator or industry association to establish mechanisms to identify and encourage the allocation of
Regulatory and Industry Association

strategy capital to sustainable sectors, assets, and projects?


Technical guidance 58 Does the Framework provide definitions, examples, and/or a taxonomy (catalogue and guidelines) of sustainable finance assets?
59 Does the Framework provide guidelines for extending green, social, or sustainability-focused loans (excluding bonds)?
60 Does the Framework provide guidelines for issuance of green, social, or sustainability bonds?
Actions

61 Does the Framework require/ask for external party verification to ensure the credibility of sustainability instruments?
Supervisory activities 62 Does the regulator or industry association monitor information reported by FIs related to green/social/sustainability investment, lending, and
and incentives other instruments to prevent greenwashing and social-washing?
63 Are there any financial or non-financial incentives for FIs to develop and grow green, social, or sustainability finance instruments?
Tracking and aggregated 64 Does the regulator or industry association collect and/or publish data from FIs or other sources about allocation of capital to green/social/
disclosure sustainability assets, projects, or sectors?

16
4
Strategy and governance 65 Does the Framework require/ask FIs to establish a strategy, governance, or high-level targets, including at the Board of Directors level, for
capital allocation to sustainable assets, projects, or sectors?
Organizational structure 66 Does the Framework require/ask FIs to define internal staff roles and responsibilities to encourage finance flows to green, social, and/or
and capacity building sustainability-focused investments?
67 Does the Framework require/ask FIs to develop and maintain internal staff capacity on green, social, or sustainability products through
regular training and learning?
Policies and procedures 68 Does the Framework require/ask FIs to put in place policies and procedures for defining, issuing, managing proceeds, tracking performance,
Expectations of FI Actions

and reporting on green, social or sustainability-focused products?


69 Does the Framework require/ask FIs to appoint an independent external reviewer to confirm that the FI’s internal framework meets the
requirements of the recognized national framework and regulations, or aligns to international standards?
70 Does the Framework require/ask that FIs create incentives for managers to increase sustainable loans or investments in the portfolio?
Tracking, reporting, and 71 Does the Framework require/ask FIs to publish annual updates on the performance and impacts of the sustainability instruments in
disclosure compliance with relevant national and/or international standards?
72 Does the Framework require/ask FIs to obtain and disclose independent review of metrics reported annually in relation to the social and
environmental outcomes and impacts achieved through the sustainability instruments?
73 Does the Framework require/ask FIs to report to the regulator(s) or industry association(s) on allocation and/or outcomes of green, social,
and/or sustainability loans?
74 Does the Framework require/ask FIs to report to the regulator(s) or industry association(s) on green, social, and/or sustainability bonds or
other positive impact investments?
75 Does the Framework require/ask FIs to report publicly on their green, social, and sustainability-focused finance activities and positive
outcomes or impacts (i.e. not only to the regulator or shareholders)?

17
Figure 1: Overall Progression Matrix Milestones

Figure 1: Overall Progression Matrix Milestones Maturing


Figure 5: Overall Progression Matrix Milestones
Implementation
Preparation Consolidating Maturing
Mainstreaming
Behavioral Changes
DevelopingImplementation
Advancing
Preparation Consolidating Mainstreaming
Commitment Formulating
Developing Advancing A comprehensive set BehavioralThere is Changes
an established
A first national Implementation tools of national Sustainable ecosystem of
TheCommitment
financial sector A formal initiative
Formulating Finance initiatives and Sustainable Finance
roadmap, framework, and initiatives are
regulator or industry — led by a financial A comprehensive
frameworks are in set There is an
initiatives established
and
policy, regulation, in place, such as
association has sector regulator or A first national Implementation tools of national
place, Sustainable
covering ecosystem ofthat align
all parts frameworks
The financiala sector A formal association
initiative or or set of voluntary guidance, guidelines,
announced formal industry roadmap,principles
framework, and initiatives are Finance
of initiatives
the financial and
system. Sustainable
and integrateFinance
with each
regulator or industry — led—byis ainfinancial industry on reporting templates,
commitment to both progress policy, regulation, in place, online
such as frameworks are in initiatives and
other.
association has on sector regulator or Sustainable Finance training, tools, The national
achieve progress to develop a national or set of voluntary guidance, guidelines, place, covering all parts frameworks that align
announced aFinance
formal industry association has been formally and supervisory frameworks aresystem.
aligned Financial institutions are
Sustainable roadmap, framework,or industry principles on reporting templates, of the financial and integrate with each
launched. instructions. with international good required
commitment
in the next two to years. both —orisvoluntary
policy, in progress
Sustainable Finance training, online tools, other. or encouraged
achieve progress on to develop
industry a national
principles on A formal The national
practice across all three to report publicly on
Initial steps have has beentaskforce
formally The
and national
supervisory frameworks are aligned their
Financial institutions are
Sustainable Finance roadmap, framework,
Sustainable Finance. or dedicated unit is Sustainable pillars of Sustainable implementation
been launched. instructions.Finance
in thetaken, such
next two as
years. policy, or voluntary leading implementation framework covers with international good of
Finance. required or encouraged
Sustainable Finance
a kick-off meeting or Preparations include
industry principles on A formal practice across all three across
to reportriskpublicly
and on
Initial stepswith
have efforts — taskforce
either within The national
multiple parts of the Consistent and
workshop key research,
Sustainable suveys,
Finance. or dedicated unit is Sustainable Finance pillars of Sustainable their implementation
opportunity.
been taken, such the regulator or financial system. comparable data is
stakeholders and as multi-stakeholder leading implementation framework covers Finance. of Sustainable Finance
a kick-off meeting or Preparations include industry association, or being collected by the The regulator or
industry. engagement, and/or efforts — either within Financial institutions
multiple parts of the across risk and
workshop with key research, suveys, as a multi-stakeholder Consistent and
regulator as part of industry association
awareness raising for the regulator report onsystem.
their opportunity.
stakeholders and multi-stakeholder working grouporor financial comparable—
supervision data is the has multi-year data
or by
the financial sector. industry association, or implementation of the
industry. engagement, and/or platform. being collected
industry by the
association, Theimplementation
on regulator or by
as a multi-stakeholder Financial institutions
roadmap, framework,
awareness raising for The Sustainable report or
policy, onvoluntary
their regulator
about as part of
implementation industry association
financial institutions
working group or supervision — or by the — hasincluding
multi-year data
the financial sector. Finance implementationin lineof the by financial institutions. both risk
platform.initiative is principles with
industry association, on implementation by
acknowledged or roadmap, framework,
consistent reporting and opportunity. Data
The Sustainable
supported by both policy, or voluntary
instructions or about implementation financial information
includes institutions
Finance initiative
regulators is
and industry. principles provided
templates in line with by financial institutions. on — including
the benefits both
of risk
acknowledged or consistent
by reporting
the financial sector and opportunity.
Sustainable Data
Finance.
Awareness
supported by raising
both and instructions
regulator or
or industry includes information
capacity
regulatorsbuilding have
and industry. templates provided
association. on the benefits of
been conducted. by the financial sector Sustainable Finance.
Awareness raising and regulator or industry
capacity building have association.
been conducted.

Figure 2: Progression Matrix Milestones – Pillar 1: ESG Integration


Figure 6: Progression Matrix Milestones – Pillar 1: ESG Integration
Figure 2: Progression Matrix Milestones – Pillar 1: ESG Integration
Maturing
Implementation
Preparation Consolidating Maturing
Mainstreaming
Behavioral Changes
DevelopingImplementation
Advancing
Preparation Consolidating Mainstreaming
Commitment Formulating
Behavioral Changes
Developing Advancing A comprehensive The national
A first national Implementation tools national initiative or set frameworks for ESG
TheCommitment
financial A formal initiative is in
Formulating of frameworks are in Integration are aligned
policy, regulation, and initiatives are
sector regulator or progress to develop A comprehensive
place that promote ESG The national
with international good
guidelines, or set of in place, such as
industry association a policy, regulation, A first national Implementation tools national initiative
Integration acrossorallset
parts frameworks for
practice ESG
and national
The announced
financial A formal initiative is in voluntary principles guidance, guidelines,
has guidelines, or voluntary policy, regulation, and initiatives are frameworks
of the financial are in
system. Integration are
regulations; andaligned
has been formally reporting templates,
asector regulatortoor
commitment progress to develop
principles on ESG guidelines,thator set place that promote ESG with international
are consistent good
across
industry aassociation a policy, regulation, launched setsof in place, online
training, such as tools,
develop policy, Integration for the voluntary principles The nationalacross
Integration frameworks
all parts practice parts
different and national
of the
out requirements guidance,
and guidelines,
supervisory
has announced
regulation, guidelines, guidelines,
financial or voluntary
sector. cover
of the all three cross-
financial system. regulations; and
has been formally
or recommendations reporting templates,
instructions. financial sector. 
a commitment
or voluntary to principles on ESG cutting areas of ESG are consistent across
Preparations launched
for financialthat sets training, online tools,
develop a for the
principles policy, Integration for the The The national frameworks
Integration: Local financial
different parts of the
include research, out requirements
institutions on ESG and ESG Integration
supervisory
regulation,
financial guidelines,
sector financial sector. expectations 1.cover all three
strategic cross-
alignment, institutions
financial sector. 
surveys, multi- or recommendations
Integration. instructions. cover cutting areasandof ESG
or voluntary
on integrating the multiple parts of the 2. regulatory demonstrate that
Preparations
stakeholder for financial
principles for the
management of A formal taskforce, The ESG system.
Integration Integration:
industry association Localhave
they financial
embedded
include research, institutions on ESG financial
financial sectorsocial,
environmental, engagement, and/ expectations cover 1. strategic
actions, andalignment, institutions
the requirements for
surveys, multi-raising working group, or
Integration.
on integrating
and governance the or awareness Financial institutions
multiple parts of the 2. expectations
3. regulatory and of demonstrate
ESG thatand
Integration
stakeholder institution is tasked
management
(ESG) risks and of for the financial sector. A formal taskforce, report
financialonsystem.
their industry association
financial institution theyreporting
are have embedded
on their
engagement, and/ with implementation
environmental,
performance social,
(ESG workingsupervision
and/or group, or implementation of actions, and
actions. the requirements for
efforts.
and governance or awareness raising Financial
ESG institutions
Integration in 3. expectations of ESG Integration and
Integration). institution
and is is tasked
supported
(ESG) risks and for the financial sector. report
line withonconsistent
their Consistent
financial andinstitution Extensive dataon their
are reporting
with
by implementation
regulators and
A first event or(ESG
performance and/or supervision implementation
reporting of
instructions comparable
actions. data are are becoming
efforts. available
industry. 
workshop
Integration). has been and is supported ESG
or Integration
templates in
provided becoming available on on trends among
held to engage Activities include linethe
with consistent Consistent
trends in theand
practices Extensiveinstitutions
financial data
by regulators and by financial sector
A first event
relevant or
financial awareness reporting or instructions comparable
of data are in
financial institutions are becoming
regarding available
practices in
industry.  raising regulator industry
workshop
sector has been
stakeholders and capacity or templates provided becoming
relation available
to ESG on
Integration on trends
ESG amongand
Integration
association.
held
on thetotopic
engageof ESG Activitiesfor
building include
financial by the financial sector trends
and theinresulting
the practices
benefits. financial
the institutions
resulting benefits.
relevant financial
Integration for the awareness on
institutions raising
the regulator or industry of financial institutions in regarding practices in
sector stakeholders
financial sector. and capacity
new expectations for association. relation to ESG Integration ESG Integration and
on the topic of ESG building
ESG for financial
Integration. 6 and the resulting benefits. the resulting benefits.
Integration for the institutions on the 18
financial sector. new expectations for
ESG Integration. 6
Figure 3: Progression Matrix Milestones – Pillar 2: Climate Risk Management
Figure 3: Progression Matrix Milestones – Pillar 2: Climate Risk Management
Figure 7: Progression Matrix Milestones – Pillar 2: Climate Risk Management
Maturing
Maturing
Implementation
Implementation Mainstreaming
Preparation Consolidating Mainstreaming
Preparation Consolidating Behavioral Changes
Developing Advancing Behavioral Changes
Developing Advancing
Commitment Formulating
Commitment Formulating A comprehensive The national frameworks
A comprehensive
national initiative or The nationalRisk
for Climate frameworks
A national policy, Implementation tools national initiative or for Climate Risk
The financial A formal initiative A national policy, Implementation tools set of frameworks Management are aligned
The financial A regulation, guidelines, or and initiatives are in
sector regulator or is formal initiative
in progress to regulation, guidelines, or and initiatives set of in frameworks Management are aligned
sector regulator or is in progress to set of voluntary industry place, such as are in
guidance, are
are
place aimed at
in placeallaimed
with international good
industry
industry
association
association
develop or refine set of voluntary
principles is in placeindustry
that place, such as guidance,
guidelines, reporting supporting partsatof with international
practice expectations goodand
has announced adevelop
national orpolicy,
refine
principles is in place that guidelines, reporting supporting
the financialallsystem
parts of
to practice expectations
national climate change and
has announcedto aregulation,
national policy, includes requirements templates, training, the financial system
a commitment
adevelop
commitment to regulation,
guidelines, includes requirements
and/or recommendations templates,
online tools,training,
and manage climate risk.to national climateand
commitments; change
are
a policy, or voluntaryguidelines,
industry and/or recommendations online tools, instructions
and manage climate risk. commitments;
consistent across anddifferent
are
develop a policy, or for the financial sector supervisory
regulation, or principles onindustry
voluntary Climate for the financial sector supervisory instructions The national frameworks consistent
parts of theacross
financialdifferent
regulation,principles
or principles on Climate to manage climate to help the financial The
covernational
all threeframeworks
cross- parts
voluntary
voluntary
Risk Management to manage climate
risk — either as part of to helpmanage
sector the financial
climate- cover allareasthreeofcross- sector.of the financial
on Climateprinciples
Risk Risk
for theManagement
financial risk cutting Climate sector.
on Climate Risk for the —financial ESG—Integration
either as partor asofa sector
relatedmanage
physicalclimate-
and cutting areas of Climate
Risk Management: Local financial institutions
Management for the sector either as ESG Integration or as a related
Management for the sector standalone framework. transition risks. and
physical Risk Management: Local financial institutions
financial sector. part of aneither
— as
existing standalone framework. transition risks. 1. strategic alignment, demonstrate that they
financial sector. part of an existing 1.2. strategic
regulatoryalignment,
and demonstrate
have embedded thatthe
they
ESG framework or A formal taskforce, Financial Institutions
Initial awareness ESG framework or A formal group,
taskforce, Financial 2. industry
regulatory and have embedded for the
Initial as a standalone working or report on Institutions
their association requirements climate
raisingawareness
and as a standalone working industry association requirements for climate
raising and sharing framework. institutiongroup, or the
is taking report
approach on their
to Climate actions, and risk management and are
knowledge
knowledge sharing
framework. institution
lead is taking the
with implementation approach
Risk to Climate
Management in 3. actions, and of
expectations risk management
reporting on their and are
efforts.
is being organized Preparations include lead with implementation Risk Management 3. expectations of reporting on their efforts.
is and/or supervision, and is line with consistentin financial institution
bybeing organized
the regulator or Preparations
research, surveys, include
and/or supervision, and is line with consistent financial institution
actions. Extensive data are
by the regulator or research, surveys, supported by regulators reporting instructions actions. Extensive
becoming data are on
available
industry association. multi-stakeholder supported by regulators reporting instructions
industry association. multi-stakeholder and industry. or templates provided Consistent and becoming
trends among available on
financial
engagement and/or and industry. or templates provided
engagement and/or by the financial sector Consistent
comparableand data are trends among
institutions financial
regarding
awareness raising for Activities include by the financial
awareness regulator and/orsector comparable data areon institutions
climate risk regarding
the financialraising
sector.for Activities
awarenessincluderaising, regulator and/or becoming available management
the financial sector. awarenessguidance
raising, and/ industry association and becoming
trends in the available on
practices climate
and the risk management
resulting benefits.
research, industry
reflectingassociation
international and trends in theinstitutions
practices and the resulting benefits.
research,
or capacity guidance
buildingand/
for reflecting international of financial
or capacity building onfor practices. of financialtoinstitutions
in relation Climate
financial institutions practices. in relation to Climate
financial institutions
managing climate-related on Risk Management and
managing climate-related Risk Management
the resulting and
benefits.
physical and transition the resulting benefits.
physical andwith
risks in line transition
the
risks in line with the
new expectations in the
new expectations
national framework. in the
national framework.

Figure 4: Progression Matrix Milestones – Pillar 3: Financing Sustainability


Figure 8: Progression
4: Progression Matrix
Matrix Milestones
Milestones – Pillar
– Pillar 3: Financing
3: Financing Sustainability
Sustainability

Maturing
Maturing
Implementation
Implementation Mainstreaming
Preparation Consolidating Mainstreaming
Preparation Consolidating Behavioral Changes
Developing Advancing Behavioral Changes
Developing Advancing
Commitment Formulating
Commitment Formulating A comprehensive The national frameworks
A comprehensive
national initiative or The national frameworks
for Financing
A national framework Implementation tools national initiative or for Financing are aligned
The financial sector A formal initiative A national set of frameworks Sustainability
The financial sector A formal initiative is in place framework
that Implementation
and initiatives are tools
set of frameworks Sustainability are aligned
regulator or industry is in progress is in placeregulations
that and initiatives are are in place aimed at with international good
regulator or has
industry is includes in place, such as
association made to in progress
develop a includes regulations in place, such as
are in placeall
supporting aimed
partsatof with international
practice expectationsgood
association has made to develop a or guidance for the guidance,guidelines, supporting
a public commitment policy, regulation, or guidance for to
the guidance,guidelines, the financialallsystem
parts of practice expectations
and national sustainable
atopublic commitment policy, regulation, financial sector taxonomies, the financialfinancial
system and national sustainable
develop a policy, guidelines, or financial sector to taxonomies, to promote development plans; and
to develop guidelines,
a policy, guidelines,principles
or promote financial reporting templates, to promote financial development
regulation, voluntary promote financial reporting templates, flows to green, social, or are consistentplans;
acrossand
regulation, flows to green, social, training, online tools,
or voluntaryguidelines,
principles voluntary
to promoteprinciples
financial flows to green, social, training, online tools,
flows to green, social, or
sustainability-focused are consistent
different parts ofacross
the
or voluntaryfinancial
principles to promote financial or sustainability- and supervisory sustainability-focused different
to promote flows to green, social, or sustainability- and supervisory projects and sectors. financial parts
sector.of the
to promote financial flows to green, social, focused projects and instructions to help projects and sectors. financial sector.
flows to green or or sustainability- focused projects and instructions
flows to green or or sustainability- sectors. the financialto help
sector The national Local financial institutions
sustainability-focused focused projects and sectors. the financial sectorflows The nationalcover all Local financial institutions
sustainability-focused focused promote financial
projects and sectors. sectors. projects and A taskforce, working promote
frameworks demonstrate that
projects and sectors. sectors. A taskforce, working to green, financial
social, orflows frameworks cover all
three cross-cutting demonstrate that
they have embedded
group, or institution to green, social, or
sustainability-focused three cross-cutting theyrequirements
have embedded
Initial awareness Preparations include group, or with
institution areas of Financing the for
Initial is tasked sustainability-focused
raisingawareness
and knowledge Preparations include
research, surveys, is tasked with projects and sectors. areas of Financing
Sustainability: the requirements
Financing for
Sustainability
raising implementation projects and sectors.
sharingand knowledge
is being research, surveys,
multi-stakeholder implementation
Sustainability:
1. strategic alignment, Financing Sustainability
in their operations,
sharing is being multi-stakeholder and/or supervision Financial institutions 1.2. strategic
organized by the engagement and/or and/or supervision Financial regulatoryalignment,
and in their operations,
portfolio, products,
organizedorbyindustry
the engagement and/or and is supported report on institutions
their 2. industry
regulatory and portfolio, products,
regulator awareness raising for and is supported report on their association and services and
regulator or industry awareness by regulators and approach to Financing
association. the financialraising
sector.for by regulators and approach to Financing
industry
actions, andassociation and services and
are reporting their
association. the financial sector. industry. Sustainability in
industry. Sustainability in 3. actions, and of FI
expectations are reporting publicly.
performance their
line with consistent 3. expectations of FI performance publicly.
Activities include line with consistent actions.
Activities reporting instructions actions. Extensive data are
awarenessinclude
raising reporting instructions Extensive
awareness raising or templates provided Consistent and becoming data are on
available
and capacity or
by templates provided Consistent
and capacity the financial sector comparableand data are becoming
trends among available on
financial
building for financial by the
regulatorfinancial
or sector
industry comparable data are trends among financial
building for financial becoming available institutions regarding
institutions on the regulator or industry
association. becoming available institutions regarding
institutions on the on trends in the Financing Sustainability
new expectations association. on trends ofin financial
the Financing Sustainability
new expectations practices and the resulting benefits.
for Financing practices of financial and the resulting benefits.
for Financing institutions in Financing
Sustainability. institutions in Financing
Sustainability. 19
Sustainability and the
Sustainability
resulting benefits. and the
7 resulting benefits.
7
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