Takeaways from the ECB’s review of banks on climate

ECB observations on how banks manage climate and environmental risk will likely inform how the U.S. reviews financial institutions.

In November 2022, the European Central Bank (ECB) reviewed European banks’ alignment with its 2020 guidance on climate-related and environmental-related financial risks[footnote 1]. U.S. financial organizations should review ECB examiner observations closely, which continue the calls for increased credibility on climate- and environment-related risk management and related disclosure.While over 90% of banks surveyed had conducted a basic materiality assessment, nearly all (96%) had blind spots, 60% of which the ECB considered to be major gaps.

KPMG has summarized the most significant takeaways of the ECB survey to help Chief Risk Officers and climate teams of U.S. financial and foreign banking organizations understand how to address them. Read the paper below to learn how ECB observations can be instructive to U.S. banks, and how KPMG can help.

How KPMG can help

We can assist your financial organization with assessing the enforcement of climate and environmental risk programs and determine their level of credibility for investors and regulators. We can also help you develop roadmaps and action plans to remediate any identified weaknesses. Our services include:

  • Develop materiality assessments of climate- and environmental-related financial risk
    • Draft or review related policies and procedures as needed
  • Help build or strengthen climate risk management programs
  • Review or revise climate risk management program to confirm processes exist
    • Integrate results of assessments into risk management and strategic planning
  • Conduct reviews of governance, risk, and reporting, and help implement findings
  • Assist with development of working groups and committees that provide information for strategy-setting, implementation plans, and reporting
  • Develop tracking mechanisms to confirm that Board-approved action plans are implemented

As investors and regulators continue to expect increased credibility of disclosure on climate and environmental risk management, it is more important than ever to stay on top of your organization’s climate risk efforts. KPMG professionals can help you assess your ongoing strategic risks and address them. Contact us to learn how we can help your team succeed in a dynamic banking regulatory environment.



  1. Source: European Central Bank, “Guide on climate-related and environmental risks: Supervisory expectations relating to risk management and disclosure” (Frankfurt, November 2022)

Contact us

Adam Levy

Adam Levy

Principal, Modeling & Valuation, KPMG US

+1 312-665-2928
Christine Livingston

Christine Livingston

Director Advisory, FS Risk, Regulatory & Compliance, KPMG US

+1 213-972-4000