Integrating ESG risks into a bank’s credit risk framework

Integrating ESG risks into a bank’s credit risk framework

On Thursday 9 June, we hosted a roundtable in our head office in Utrecht titled ’Integrating ESG risks into a bank’s credit risk framework’. The roundtable was attended by credit and climate risk managers, as well as model validators, working for Dutch banks of different sizes. In this article we briefly describe Zanders’ view on this topic and share the key insights of the roundtable.

The last three to four years have seen a rapid increase in the number of publications and guidance from regulators and industry bodies. Environmental risk is currently receiving the most attention, triggered by the alarming reports from the Intergovernmental Panel on Climate Change (IPCC). These reports show that it is a formidable, global challenge to shift to a sustainable economy in order to reduce environmental impact.

Zanders’ view

Zanders believes that banks have an important role to play in this transition. Banks can provide financing to corporates and households to help them mitigate or adapt to climate change, and they can support the development of new products such as sustainability-linked derivatives. At the same time, banks need to integrate ESG risk factors into their existing risk processes to prepare for the new risks that may arise in the future. Banks and regulators so far have mostly focused on credit risk.

We believe that the nature and materiality of ESG risks for the bank and its counterparties should be fully understood, before making appropriate adjustments to risk models such as rating, pricing, and capital models. This assessment allows ESG risks to be appropriately integrated into the credit risk framework. To perform this assessment, banks may consider the following four steps:

  • Step 1: Identification. A bank can identify the possible transmission channels via which ESG risk factors can impact the credit risk profile of the bank. This can be through direct exposures, or indirectly via the credit risk profile of the bank’s counterparties. This can for example be done on portfolio or sector level.
  • Step 2: Materiality. The materiality of the identified ESG risk factors can be assessed by assigning them scores on impact and likelihood. This process can be supported by identifying (quantitative) internal and external sources from the Network for Greening the Financial System (NGFS), governmental bodies, or ESG data providers.
  • Step 3: Metrics. For the material ESG risk factors, relevant and feasible metrics may be identified. By setting limits in line with the Risk Appetite Statement (RAS) of the bank, or in line with external benchmarks (e.g., a climate science-based emission path that follows the Paris Agreement), the exposure can be managed.
  • Step 4: Verification. Because of the many qualitative aspects of the aforementioned steps, it is important to verify the outcomes of the assessment with portfolio and credit risk experts.

Key insights

Prior to the roundtable, Zanders performed a survey to understand the progress that Dutch banks are marking with the integration of ESG risks into their credit risk framework, and the challenges they are facing.

Currently, when it comes to incorporating ESG risks in the credit risk framework, banks are mainly focusing their attention on risk identification, the materiality assessment, risk metric definition and disclosures. The survey also reveals that the level of maturity with respect to ESG risk mitigation and risk limits differs significantly per bank. Nevertheless, the participating banks agreed that within one to three years, ESG risk factors are expected to be integrated in the key credit risk management processes, such as risk appetite setting, loan origination, pricing, and credit risk modeling. Data availability, defining metrics and the quantification of ESG risks were identified by banks as key challenges when integrating ESG in credit risk processes, as illustrated in the graph below.

In addition to the challenges mentioned above, discussion between participating banks revealed the following insights:

  • Insight 1: Focus of ESG initiatives is on environmental factors. Most banks have started integrating environmental factors into their credit risk management processes. In contrast, efforts for integrating social and governance factors are far less advanced. Participants in the roundtable agreed that progress still has to be made in the area of data, definitions, and guidelines, before social and governance factors can be incorporated in a way that is similar to the approach for environmental factors.
  • Insight 2: ESG adjustments to risk models may lead to double counting. The financial market still needs to gain more understanding to what extent ESG risk factor will manifest itself via existing risk drivers. For example, ESG factors such as energy label or flood risk may already be reflected in market prices for residential real estate. In that case, these ESG factors will automatically manifest itself via the existing LGD models and separate model adjustments for ESG may lead to double counting of ESG impact. Research so far shows mixed signals on this. For example, an analysis of housing prices by researchers from Tilburg University in 2021 has shown that there is indeed a price difference between similar houses with different energy labels. On the other hand, no unambiguous pricing differentiation was found as part of a historical house price analysis by economists from ABN AMRO in 2022 between similar houses with different flood risks. Participating banks agreed that further research and guidance from banks and the regulators is necessary on this topic.
  •  Insight 3: ESG factors may be incorporated in pricing. An outcome of incorporating ESG in a credit risk framework could be that price differentiation is introduced between loans that face high versus low climate risk. For example, consideration could be given to charging higher rates to corporates in polluting sectors or ones without an adequate plan to deal with the effects of climate change. Or to charge higher rates for residential mortgages with a low energy label or for the ones that are located in a flood-prone area. Participating banks agreed that in theory, price differentiation makes sense and most of them are investigating this option as a risk mitigating strategy. Nevertheless, some participants noted that, even if they would be able to perfectly quantify these risks in terms of price add-ons, they were not sure if and how (e.g., for which risk drivers and which portfolios) they would implement this. Other mitigating measures are also available, such as providing construction deposits to clients for making their homes more sustainable.


Most participating banks have made efforts to include ESG risk factors in their credit risk management processes. Nevertheless, many efforts are still required to comply with all regulatory expectations regarding this topic. Not only efforts by the banks themselves but also from researchers, regulators, and the financial market in general.

Zanders has already supported several banks and asset managers with the challenges related to integrating ESG risks into the risk organization. If you are interested in discussing how we can help your organization, please reach out to Sjoerd Blijlevens or Marije Wiersma.

1) ‘The causal chains that explain how these [ESG] risk drivers impact institutions through their counterparties and invested assets.’ Source: EBA report on management and supervision of ESG risks for credit institutions and investment firms