ISDA/IIF Responds to the PRA Consultation (CP10/25) on Enhancing Banks’ and Insurers’ Approaches to Managing Climate-Related Risks

On July 30th, ISDA and IIF responded to the PRA consultation (CP10/25) on enhancing banks’ and insurers’ approaches to managing climate-related risks, which proposes updates to the Supervisory Statement 3/19 on climate-related risk management for banks and insurers.

ISDA and IIF broadly support the PRA’s climate risk approach, but we warn against overly prescriptive or bespoke climate-specific requirements.

A key theme in the industry response is integrating climate risk into existing risk frameworks rather than creating standalone processes. We also call for flexibility in governance, scenario analysis, reverse stress testing, and data expectations, especially to accommodate diverse business models and international firms. Alignment with global standards and practical implementation are also of paramount importance as the PRA finalizes its supervisory statement on climate-related risk management.

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