Financial sector

​

For banks, insurers and asset managers, sustainability now runs through risk management, investment and product development alike. BaFin defines sustainability risks as environmental, social or governance events or conditions that can damage a supervised firm's assets, financial position, earnings or reputation. For banks that means climate risks can materialise as physical risks in the form of damage to assets, or as transition risks in the rapid devaluation of carbon-intensive assets. At the same time, growing demand for sustainable products opens up market opportunities.

​

This page brings together what applies across the financial sector as a whole. The more detailed, institution-specific regulation sits on the individual competency pages.

​

The regulatory framework for banks

​

The German act transposing the EU banking package and cutting administrative burden (BRUBEG), promulgated on 30 March 2026, brought CRD VI into German law. ESG risks are now anchored in the German Banking Act (KWG) as a binding requirement for the first time. Section 26c KWG requires institutions to integrate ESG risks systematically, and Section 26d KWG mandates an institution-specific ESG risk plan. This is complemented by the EBA Guidelines on the management of ESG risks and on environmental scenario analysis, which apply from 2026 and 2027 respectively and make climate stress tests and resilience assessments binding.

​

The regulatory framework for insurers

For insurers, the German act amending insurance recovery, resolution and supervision law (VSAAG) serves a comparable function to the BRUBEG for banks. The ministerial draft transposes the revised Solvency II Directive and strengthens the integration of sustainability and climate risks into insurance supervision. Application is planned from 30 January 2027.

​

Disclosure obligations across all three types of institution

​

Banks, insurers and asset managers share the same core disclosure obligations but carry different additional metrics on top.

​

Banks report the Green Asset Ratio. Disclosure through the taxonomy-related Pillar 3 templates is suspended until the end of 2026 on the EBA's recommendation, and the amended implementing technical standards have been available since June 2026. The first disclosure reference date is 31 December 2026.

​

Insurers report an investment KPI and an underwriting KPI for their non-life business. Because methodologies diverge, the figures are barely comparable between firms.

​

Asset managers report the share of taxonomy-aligned investments in their assets under management. Their data base is shrinking, because the narrower CSRD scope means fewer investee companies report in their own right.

​

For their SFDR disclosures, and for the PAI indicators in particular, all three need reliable emissions data from their investee companies.

​

Our topics for the financial sector

​

• ESG risk integration and scenario analysis: We assess your risk management processes against the EBA Guidelines and develop climate stress tests and resilience assessments tailored to your material risks. → Climate risks

• Regulatory risk documentation: We translate the results into the documents actually required, the ESG risk plan under Section 26d KWG for banks and the ORSA for insurers. → ESG risk plan

• Financed and insured emissions: We account for your lending, investment and underwriting portfolio under PCAF, including data quality classification and audit-ready documentation. → Carbon accounting

• Taxonomy KPIs: We do the groundwork for your Green Asset Ratio, your underwriting KPI or your taxonomy share of assets under management, depending on your type of institution. → EU Taxonomy

• SFDR disclosure: We build the process for the PAI indicators and for product-level disclosure, and prepare the move to SFDR 2.0. → SFDR

• Sustainable financial products: We support you in designing green and sustainability-linked products, from the target architecture through to the criteria for later disclosure.
   

How we work

​

• Start with your type of institution: We first establish which requirements actually govern your firm. Banks, insurers and management companies differ considerably in legal basis, deadline and metric.

• One data set, several uses: Risk management, taxonomy KPIs and SFDR disclosure all draw on the same portfolio emissions data. We collect it once and keep assumptions and reference dates consistent across every use.

• Workshops and training: We show your team in practical terms how to implement the requirements relevant to your institution.
   

Contact us
 

Whether it is ESG risk integration, taxonomy KPIs or developing sustainable financial products, we will work out with you where you stand and which step makes sense next.