Key milestones

  • SFDR applies from March 10, onwards.
  • On April 21, the European Commission published a proposal for the CSRD, revising the NFRD.
  • Level 1 SFDR reporting deadline of June 30 applies to FMPs.
  • Adoption of the proposal for a EU Green Bond Standard and the renewed Sustainable Finance Strategy on July 6.
  • Publication of the Disclosures Delegated Act and Climate Delegated Act of the EU Taxonomy.
  • Benchmark providers need to report on how methodology aligns with Paris Agreement targets.
  • From January SFDR RTS apply.
  • EBA published Pillar 3 draft ITS
  • EFRAG published first European Sustainability Reporting Standards (ESRS)
  • As of June, banks must report on physical and transitory climate risks under CRR (EU) 2013/575
  • MiFID II delegated regulation requires investment advisors to consider clients’ sustainability preferences.
  • ECB Stress Test on resilience of European banks to shocks from physical and transitional climate risks.
  • European Commission will adopt first set of ESRS.
  • First mandatory reporting on Taxonomy alignment by corporates and eligibility by FMPs for the financial year 2022.
  • Publication of the Environmental Delegated Act, expanding the EU Taxonomy to all six environmental objectives.
  • SFDR reporting deadline for FMPs, including additional requirements under the SFDR RTS.
  • European Commission will adopt second set of ESRS.
  • In-scope companies will publish first reports reflecting new reporting requirements under CSRD, covering financial year 2023.
  • Listed SMEs, excluding micro enterprises, may voluntarily disclose KPIs and targets until it becomes mandatory from 2027, for the financial year 2026, onwards.
  • SMEs disclose voluntarily KPIs/Targets.

Innovation - published IBM article in Sept 2021

A constantly evolving path in Sustainability and Climate Risk obligations for German Banking & Financial Markets – but the direction is unmistakable

To say that the past 3 months brought sustainability and climate risks to the forefront of social and political life in Germany would be an understatement. The most important task right now is to assuage people’s suffering and restore a sense of normality to the areas most affected by the devastating July floods. What should not be forgotten, though, is that the political and economic institutions (both within and outside Germany) have also been evolving quite significantly in the same timeframe, as if to keep apace in a relentless race against time.

Read article →

Marinela Bilic-Nosic

Executive Partner Banking
Regulatory, Risk, Compliance Lead DACH

Johannes Giannakouros

Risk, Legal & Regulatory Compliance Advisory


    • Provide services to access data insights
    • Enable faster data driven decision making
    • Ensure data quality
    • Manage internal and external data sources


    • How to build AI models?
    • What data analytics tools are available?
    • How to manage the data quality?
    • How to access external data sources?
    • Where to host the data and the analytics?
    • How do I create operationalise a data science service?

    Climate change

    • Carbon emissions
    • Product Carbon Footprint
    • Financing Environmental Impact
    • Climate Change Vulnerability

    Natural capital

    • Water stress
    • Biodiversity & Land Use
    • Raw Material Structuring


    • Toxic Emissions & Waste
    • Packaging Material & Waste
    • Electronic Waste

    Environment Opportunities

    • Opportunities in Clean Tech, Green Building & Renewable Energy

    Human Capital

    • Labor Management
    • Health & Safety
    • Human Capital Development
    • Supply Chain Labor Standards

    Product Liability

    • Product Safety & Quality
    • Chemical Safety
    • Privacy & Data Security
    • Responsible Investment
    • Insuring Health & Demographic Risk

    Stakeholder Opposition & Social Opportunities

    Corporate Governance

    • Board
    • Pay
    • Ownership
    • Accounting

    Corporate Behavior

    • Business Ethics
    • Anti-Competitive Practices
    • Corruption & Instability
    • Financial System Instability
    • Tax Transparency

    Regulatory deep dive


    The architecture of European banking supervision

    European banking supervision is based on cooperation between the ECB & national supervisors

      Distribution of tasks within the SSM

      • The Single Supervisory Mechanism (SSM) is one of the largest banking supervisory authorities in the world
      • Currently 125 banking groups in 19 countries are under direct ECB supervision
      • Around 3,200 smaller institutions are directly supervised by the National Competent Authorities (NCAs), with the ECB being responsible for the system at large
      • Banking assets under direct and indirect ECB supervision amount to more than 26 trillion Euros about 2.6 times euro-area GDP

      Read source

      What exactly do supervisors look at?

      1. Business model
      2. Internal governance
      3. Risks to Capital
      4. Risks to Liquidity

      Read source

      Annual stress tests

      • EU law requires the ECB to carry out stress tests on supervised banks at least once per year
      • The results of annual stress tests provide important input to the SREP process for the test year
      • EU-wide stress tests - Every two years the EBA carries out EU-wide stress tests
      • Thematic stress tests - In years when there is no EU-wide EBA stress test the ECB tests significant institutions under its direct supervision against a specific kind of shock (2022 Climate Risk Stress Test)

      Read source

      What informs the Supervisory Review and Evaluation (SREP) process?

      • Stress tests: Supervisors use stress tests to identify and address banks’ vulnerabilities early on in the SREP process
      • Supervisory priorities: Every year ECB Banking Supervision sets its supervisory priorities that will guide the SREP in the year ahead
      • Risk assessment: Every year ECB Banking Supervision identifies and assesses the risks banks face to determine focus areas for the SREP

      Read source


      Climate Risk Stress Test

      Discover how IBM helps prepare for ECB Climate Risk Stress Test in 2022

      We offer a wide range of climate change and sustainability professionals

      IBM tools such as the CO2 Calculator help banks prepare for the ECB climate stress test by running climate stress test simulations in advance

      We support your establishment of holistic ESG risk management

      We analyze your regulatory and economic risk management process

      We support you in collecting the required data to successfully complete the ECB climate risk stress test in 2022

      We help identify the critical climate risks to your business and provide recommendations for developing resilience


      Let's talk!

        Marinela Bilic-Nosic

        Executive Partner Banking

        Regulatory, Risk, Compliance Lead DACH
        +49 173 7206070

              Christina Rohschürmann

              Senior Managing Consultant

              Banking & Financial Markets

              +49 172 2665833