Net-zero commitments by financial institutions may create legal and reputational risks when stated targets are not matched by credible progress. This report presents a monitoring framework for assessing risks related to financial institutions’ net-zero commitments. The framework includes quantitative and qualitative assessments focused on governance and risk-management practices. It analyses public disclosures by Dutch and other European financial institutions, considers supervisory data available to De Nederlandsche Bank, and identifies comparability and data-quality challenges that may hinder risk assessment.
The report explores how sector-level physical emissions-intensity metrics can provide a suitable basis for assessing alignment with net-zero commitments, and thereby legal and reputational risks. It also identifies opportunities to improve reporting in a cost-effective manner and deprioritise disclosures that may be costly but have limited relevance for assessing potentially material risks.
