Net‑Zero Commitments and Prudential Risks in the Dutch Financial Sector

Annex B. Details on disclosure frameworks and reporting of financial institutions in practice

Corporate Sustainability Reporting Directive (CSRD) and International Financial Reporting Standards (IFRS)

The CSRD supports the EU’s goal of achieving carbon neutrality by 2050 by improving corporate transparency on sustainability, including climate-related disclosures relevant to assessing transition risks. To meet CSRD requirements, companies must report information in line with the ESRS, covering a broad range of environmental, social, and governance issues, including climate change, biodiversity and human rights.

As of the end of 2024, the ESRS are the most frequently adopted standard, used by 46% of the jurisdictions covered by the OECD Corporate Governance Factbook (OECD, 2025[1]). The International Financial Reporting Standards (IFRS) Sustainability Standards set by the International Sustainability Standards Board (ISSB) are the second most commonly used sustainability standards, adopted by 17% of OECD Factbook jurisdictions.

Table A B.1 illustrates the interoperability between the ESRS E1 Climate Change and the IFRS S2 Climate-related Disclosures for a set of defined climate-related metrics, showing commonalities covered by these frameworks (OECD, 2026[2]). However, there is limited alignment on specific metrics and calculation methods to assess the progress of financial institutions towards their net-zero targets. For each metric, the table indicates whether it is required by the ESRS E1 and the IFRS S2, and whether it is available from the major commercial data providers (LSEG, Bloomberg, Morningstar, and MSCI). The existence of disclosure requirements in those standards may signal that any data gaps for the relevant metrics and information points would be expected to be reduced soon with the broader adoption of the ESRS E1 and the IFRS S2.

Table A B.1. Most commonly reported information and metrics for financial institutions in IFRS S2 and ESRS E1

Climate-related metrics	IFRS S2	ESRS E1	Availability by commercial data providers
GHG emission metrics
Historic and current absolute GHG emissions	IFRS S.2.29(a) IFRS S2.B19–B63	ESRS E1.6 (44-52) ESRS E1.6 (531-55) ESRS E1.AR39-52	Commonly available
GHG emission targets (short, medium and longterm)	IFRS S2.33-37	ESRS E1.4 (30) ESRS E1.4 (34) ESRS E1.AR23-31	Commonly available
GHG emissions intensity2	IFRS S2.33 IFRS S2. B66	ESRS E1.4 (53) ESRS E1.5 (40) ESRS E1.6 (34a)	Not available
Alignment assessment with a benchmark, incl. Paris Agreement	IFRS S.22(b)	ESRS E1.16(a) ESRS E1.AR5	Not available
Use of offsets (current and future)	IFRS S2.36(e)	ESRS E1.7 E1.AR56-64	Not available
Portfolio composition metrics
Portfolio share in low GHG assets and climate solutions	IFRS S2.16(c) IFRS S.2.29(e)	ESRS E1.16(c)(e)	Not available
Portfolio share in assets consistent with net-zero, or with targets assessed on alignment	IFRS S2.16(c) IFRS S.2.29(e)	ESRS E1.16(c)	Not available
Portfolio share in carbon-intensive assets and assets exposed to transition risks and phase out	IFRS S.2.29(b)(c)(e)	ESRS E1.16(d)	Not available
Investment allocation practices driving GHG emissions reductions	--	ESRS E1.16(b)	Not available
Overall portfolio composition and sector coverage	IFRS S.2.29(e)	--	Not available
Engagement metrics
General engagement/stewardship practices	--	--	Commonly available
Voting procedures and practices	--	--	Not available
Engagement escalation process	--	--	Not available
Collaborations and alliance engagements	IFRS S.22(b)	ESRS E1.16(a) ESRS E1.AR5	Commonly available
Advocacy-based activities	--	--	Not available
Strategy and governance metrics
Remuneration linked to climate performance	IFRS S.2.29(g)	ESRS 2 GOV-3 (13)	Commonly available
Management/Board oversight and accountability	IFRS S.2.6(a)(b)	ESRS E1.13	Commonly available
Integration of climate considerations in internal reporting and analytical processes	IFRS S.2.6(b)(ii) IFRS S.2.15-21 IFRS S.2.22 IFRS S.2.24-26	ESRS E1.20-25 ESRS E1.26-29 ESRS E1.65-70 ESRS E1.AR8 ESRS E1.AR11-12 ESRS E1.AR13-15 ESRS E1.AR70-74	Not available
Integration of climate considerations in strategic decision-making and investment strategies	IFRS S.2.14(a)	ESRS E1.26 ESRS E1.28 ESRS E1.AR31	Commonly available
General strategy on climate goals and transition plans	IFRS 2.14(a)(b)(c)	ESRS E1.1 (14-15) ESRS E1.19 ESRS E1.26 ESRS E1.28 ESRS E1.AR1-2 ESRS E1.AR8 ESRS E1.AR31	Commonly available

1. According to ESRS E1.53, companies shall disclose the GHG emission intensity based on net revenue.

2. While ESRS E1 specifically refers to net revenue-based emissions intensity, IFRS S2 does not prescribe any specific intensity-based measure.

Source: OECD (2026[2]), Mapping climate-related metrics in the financial sector, https://doi.org/10.1787/e91736e8-en

EBA Pillar 3 climate risk disclosure requirements

The EBA Pillar 3 ESG disclosure framework provides a structured and standardised set of information points that can support assessment of transition risks – such as asset stranding. Notably through Templates 1, 2 and 4. These templates allow supervisors to identify where and how transition risks may materialise on banks’ balance sheets.

Template 1 enables a sector-by-sector assessment of banks’ exposures to non-financial corporations, based on harmonised economic activity classifications. It combines information on the size of exposures with indicators of credit quality (such as the share of exposures that have experienced a significant increase in credit risk or are non-performing – i.e. where the borrower is unlikely to repay in full or is more than 90 days past due), financed emissions, accumulated impairments and remaining maturities. This information allows supervisors to assess whether carbon-intensive sectors also exhibit signs of elevated credit risk or long-dated exposures, which may be particularly vulnerable to tightening climate policies, technological disruption or demand shifts.

Template 2 links real estate-backed lending exposures to the energy efficiency of the underlying collateral, using both qualitative labels and quantitative energy-consumption indicators, while also disclosing the extent of missing or estimated data. This enables supervisors to identify banks with a material share of collateral that may be exposed to transition risks stemming from building-related climate policies, such as stricter efficiency standards or renovation requirements, which could adversely affect collateral values.

Template 4 provides information on banks’ aggregate exposure to the world’s highest-emitting corporates, including the size and maturity of such exposures. This allows supervisors to assess concentration risks linked to a small number of globally significant emitters whose business models may face structural challenges in a net-zero transition. High exposure to such counterparties may amplify credit, market and reputational risks in the event of abrupt policy or market adjustments.

Taken together, these templates allow supervisors to form a risk-focused view of banks’ transition exposure, complementing alignment metrics by highlighting where deviations from net-zero pathways could translate into financially material prudential risks.

Table A B.2 provides an overview of all quantitative templates and their purpose for assessing climate-related financially material risks.

Table A B.2. EBA Pillar 3 ESG risk disclosure templates

Template number	Information points and key financial risks
Template 1 (transition risks)	Standardised, sector-by-sector breakdown of banks’ banking book exposures to non-financial corporations, based on their NACE economic activity codes. Uniform for all banks. Including the gross carrying amount, financed emissions (Scope 1, 2, and 3), the proportion of exposures in Stage 21 and classified as Non-Performing2 (NPE), accumulated impairment, and the remaining maturity profile broken down into buckets of less than or equal to 5 years, 5-10 years, 10-20 years, and over 20 years, and including their weighted average.
	Credit risk arising from increases in the probability of default (PD) and the loss given default (LGD) of counterparties, especially for low credit quality and long-term exposures. Market risk deriving from adverse changes in the fair value of financial assets, especially for long-term positions, more exposed to abrupt repricing and higher volatility driven by transition-related shocks.
Template 2 (transition risks)	Standardised breakdown of real estate-backed loan book, linking the gross carrying amount of these exposures directly to the energy efficiency of the underlying property collateral. Link quantitative energy consumption (kWh/m²) and qualitative Energy Performance Certificate (EPC) labels (from A to G), while highlighting the volume of exposures with missing official labels and the percentage of data that is estimated. Allows central banks to identify which institutions have significant collateral value at risk from climate transition policies, such as mandatory building renovations or carbon taxes, which could render inefficient "brown" properties more costly to operate / less valuable.
	Credit risk due to collateral depreciation and potential stranded assets, increasing LGD.
Template 3 (transition risks)	Sector-level alignment metrics that compare financed activities against science-based net-zero emissions-intensity pathways. Typically includes baseline year, current metric value, interim targets (often 2030), and an indication of the distance to target and/or alignment with the reference pathway, alongside explanations of methodology, scope and data coverage. Enables supervisors to assess whether banks’ material sector exposures are evolving in line with Paris Agreement-consistent decarbonisation trajectories.
	Credit risk arising from higher PD and LGD of counterparties. Reputational risk from loss of confidence and image deterioration due to targets’ misalignment. Legal and compliance risk deriving from potential climate litigation and greenwashing.
Template 4 (transition risks)	Aggregate exposure to the 20 corporations worldwide with the highest absolute carbon emissions. Includes the total gross carrying amount of these exposures, their percentage of the total banking book, the portion classified as "environmentally sustainable," and the average maturity. Allows central banks to identify the according risk, ensuring no single institution is overexposed to a handful of "carbon giant" counterparties whose business models could be fundamentally at odds with a net-zero transition.
	Credit risk deriving from impairment of their credit quality and eventually credit losses. Market risk arising from potential equity devaluation and abrupt repricing as markets anticipate transition policies Reputational risk deriving from exposures to allegedly controversial companies. Legal risk arising from potential climate litigation and greenwashing exposures.
Template 5 (physical risks)	Exposures that are potentially vulnerable to physical climate risks, distinguishing between acute hazards (e.g. floods, storms, wildfires) and chronic hazards (e.g. heat, sea-level rise). Structured view of the volume and share of exposures subject to these risks, typically by relevant asset classes/counterparties and geographic breakdowns, and may include information on risk assessment approaches and data limitations. Allows supervisors to identify banks with comparatively higher concentrations of physically exposed assets and to gauge where physical risk could translate into credit, market or operational risk channels.
	Credit risk arising from higher PD and LGD of counterparties. Market risk due to higher market volatility. Operational risk deriving from physical disruption and business continuity impacts.
Templates 6-9 (EU taxonomy-aligned exposures)	Share of their activities that are aligned with the EU Taxonomy, including the calculation of taxonomy KPIs such as the GAR and the BTAR, and related breakdowns of taxonomy-aligned exposures.
	Reputational risk due to loss of confidence and image deterioration. Compliance risk deriving from disclosure failure and greenwashing exposures.
Template 10 (climate mitigation actions not covered in the EU Taxonomy)	Climate mitigation actions and exposures that contribute to transition objectives but are not captured as taxonomy-aligned, such as certain green bonds and sustainability-linked products. Provides visibility on the scale of banks’ mitigation-related activities beyond the Taxonomy perimeter and can be used to understand how institutions support decarbonisation outside the Taxonomy.
	Reputational risk due to loss of confidence for lack of mitigation actions.

Notes: Black text summarises the information each EBA template requires banks to disclose. Blue text is the OECD's attribution of the prudential risks that the disclosed information may help assess; it is indicative and not exhaustive.

1. Loans classified as Stage 2 represent exposures with a significant increase in credit risk since initial recognition.

2. Non-performing loans represent loans where the borrower is unlikely to repay in full or is more than 90 days past due.

Source: EBA (2025[3]), Final Report - Guidelines on the management of environmental, social and governance risks, https://www.eba.europa.eu/sites/default/files/2025-01/fb22982a-d69d-42cc-9d62-1023497ad58a/Final%20Guidelines%20on%20the%20management%20of%20ESG%20risks.pdf; (EBA, 2022[4]), EBA publishes binding standards on Pillar 3 disclosures on ESG risks, https://www.eba.europa.eu/publications-and-media/press-releases/eba-publishes-binding-standards-pillar-3-disclosures-esg, except for the risk assessment in the second column.

The disclosures enable a comprehensive assessment of credit risk (e.g. through exposures to high-carbon sectors and stranded assets), market risk (e.g. through valuation impacts on carbon-intensive assets), liquidity risk (e.g. through potential capital flight from transition-exposed portfolios), and different operational risk (e.g. through physical damage to assets and business continuity disruptions).

Central banks can refer to the EBA Pillar 3 ESG risk disclosure for assessing risks stemming from stranded assets, hard-to-abate sectors and high-carbon assets (templates 1 to 4) and risks arising from a lack of climate adaptation and physical exposure and vulnerability to climate events (template 5). Specifically, the information disclosed in template 3 enables monitoring alignment of financed emissions with physical emissions-intensity pathways.

Templates 6 to 10 allow for measuring the proportion of a bank’s financing to EU Taxonomy-aligned activities.

Detailed reporting of financial institutions in the UK and Italy

Banks

The analysis presents information from the sustainability and annual reports of two large European banks, one based in Italy and one in the United Kingdom, each among the largest banks by total assets in their respective countries.

Generally, the British bank’s reporting provides fewer data points than the Italian bank and the largest Dutch banks. The British bank lacks coverage of several key economic sectors and does not report measures of financial and emissions exposure for some of the industries that are present in the report. The Italian bank’s emissions disclosure is more comprehensive and comparable to the most complete sustainability-related disclosure by Dutch banks.

United Kingdom

Table A B.2 provides an overview of the emissions metrics and targets set by the British bank. These emissions are reported for industries considered to have high and hard-to-abate emissions. However, residential and commercial real estate portfolios, which may constitute a substantial portion of total assets and financed emissions, are not covered in the bank’s recent publications. The bank also does not disclose the absolute financed emissions attributable to each sector – except for oil and gas, and thermal coal and mining - nor the monetary exposure to individual carbon-intensive sectors. As a result, the absence of complete financial and emissions exposure data limits the ability to prioritise exposures based on both monetary size and emissions contribution.

The British bank sets a 2030 decarbonisation target range based on the International Energy Agency’s (IEA) Net Zero Emissions (NZE) and Announced Pledges Scenario (APS). The NZE describes a pathway to net zero CO₂ emissions by 2050, consistent with limiting warming to 1.5°C and the goals of the Paris Agreement. The APS reflects full implementation of all national energy and climate targets and is associated with a 1.7°C temperature rise by 2100. All intermediate targets are based on global net-zero pathways. Given that the bank operates a globally diversified portfolio, the use of global pathways may represent a pragmatic approximation. A more precise target-setting approach would align decarbonisation pathways with the bank’s actual geographic exposure across sectors. In practice, it is difficult to assess the suitability of the chosen approach because the bank does not disclose the geographical composition of its sectoral exposures.

For the sectors on which the bank reports emissions metrics, it assigns PCAF data-quality scores ranging between 2.2 and 3.0, indicating that the estimates are primarily based on borrower-level data, supplemented only where necessary with modelled estimates and industry averages.

For its asset management operations, the bank has set targets aligned with the UK Sustainability Disclosure Requirements that broadly mirror the climate-related reporting obligations under the SFDR, as explained in the main text of this report. In 2023, the bank reported a WACI reduction of 44% from the 2019 baseline. Further, the bank has set a target to reduce this metric by 50% by 2030 relative to the 2019 baseline. The reported WACI is associated with a PCAF data-quality score of 2.3, reflecting that emissions estimates are partly derived from modelled data where company-reported emissions are unavailable.

Table A B.3. Emissions reporting of a large British bank

Economic sector	Financed emissions (2023, tCO2e)	% exposure (emissions)	Assessment against net-zero pathway	Intensity metric	Latest reported (2023)	Interim (2030) target range1
Residential real estate	-	-	No target set	Not reported	Not reported	Not reported
Commercial real estate	-	-	No target set	Not reported	Not reported	Not reported
Oil and gas	23 200 000	-	IEA NZE (2024 update)2	tCO2e		14% - 30% reduction vs. baseline
Power and utilities	-	-	IEA NZE (2024 update)	tCO2e/GWh	349	195 - 270
Cement	-	-	IEA NZE (2024 update)	tCO2e/t cement	0.59	0.47 – 0.56
Iron and steel	-	-	IEA NZE (2024 update)	tCO2e/t steel	2.1	1.29 – 1.52
Aviation	-	-	IEA NZE (2024 update)	tCO2e/million rtk	79.6	709 - 776
Automotive	-	-	IEA NZE (2024 update)	tCO2e/million vkm	152.4	66 – 95
Thermal coal mining	1 440 000	-	IEA NZE (2024 update)	tCO2e	1.44	70% reduction vs. baseline

1. With the lower bound representing NZE and the upper bound APS targets.

2. The bank states that its targets align with the latest net-zero pathways of the IEA, updated in 2024.

Source: Company reporting.

Italian bank

Table A B.4 presents the emissions reporting and targeting practices of one of the major Italian banks across key economic sectors. It provides a granular mapping of financial exposure and financed emissions, enabling assessment prioritising based on monetary exposure and emissions contribution. Oil and gas, residential real estate, and power generation are the most significant in terms of financed emissions and residential real estate is by far the largest category when evaluated by financial metrics. Detailed information on both the financial and emissions-based size of each industry can reduce uncertainty and potential blind spots for the bank as well as regulators.

The Italian bank reports on physical emissions intensities for most sectors in addition to the sectors’ total financed emissions. This practice is consistent with net-zero alignment, which the bank benchmarks and targets using the IEA’s Net-zero Scenario and other industry-specific, science-based frameworks. Coal mining is not covered by a physical intensity metric; however, it has targeted full divestment from coal mining activities by 2030. All the provided economic sectors have corresponding targets for 2030, which supports the bank’s alignment with net-zero objectives.

Unlike several of the largest banks in the Netherlands, the Italian bank does not opt to align with the CRREM benchmarks for its real estate assets. Instead, the bank aligns its commercial real estate with a group-specific pathway calculated by the SBTI tool and its residential real estate with a pathway described as “specific to the portfolio”. Coal mining exposure is low and addressed through a divestment-based zero-emissions approach rather than an intensity-reduction pathway, reflecting a clear exit strategy from the sector.

Table A B.4. Emissions reporting of a large Italian bank

Economic sector	% total loans exposure (2024)	Financed emissions (2024, tCO2)	% exposure (emissions)	Assessment against net-zero pathway	Intensity metric	Latest reported (2024)	Interim (2030) target
Agriculture - Primary farming	0.69%	700 000	3.43%	Yes – Europe Avg. NGFS NZ 2050	tCO2e/mEUR revenue	675	641
Aluminium	0.31%	400 000	1.96%	Yes – IEA NZE 1.5° (2021)	tCO2e/t aluminium	4.38	4.31
Automotive	1.00%	1 000 000	4.90%	Yes – IEA Net Zero Scenario	gCO2e/vkm	192	100
Cement	0.15%	600 000	2.94%	Yes – IEA Net Zero Scenario	tCO2e/t cement	0.64	0.5
Coal mining	0.01%	100 000	0.49%	No	EUR billion exposure	0.01	0
Commercial real estate	5.95%	500 000	2.45%	Yes – bank-specific, SBTi tool	kgCO2e/m2	38.94	22.11
Iron and steel	0.69%	1 000 000	4.90%	Yes – bank- specific, SBTi tool	tCO2e/t steel	0.82	0.81
Oil and gas	2.78%	12 600 000	61.76%	Yes – IEA Net Zero Scenario	gCO2e/MJ	64	55
Power generation	5.64%	1 500 000	7.35%	Yes – IEA Net Zero Scenario	kgCO2e/MWh	123	110
Residential real estate	82.77%	2 000 000	9.80%	No	kgCO2e/m2	28.77	19.26

Source: Company reporting.

Asset managers

As in the Netherlands, selected asset managers in the United Kingdom and Italy report less detailed and wide-ranging information than banks in the same jurisdictions. Below, the analysis covers the reporting practices of two large European asset managers, one British and one Italian. Both are among the largest domestic asset managers by assets under management in their respective countries. The British asset manager provides emissions information for a set of relevant sectors and physical intensity measures for a subset of assets, while the Italian asset manager only provides a few specific points of insight on its associated emissions. Notably, the British asset manager reports WACI at the sector level, which provides a more granular view of portfolio emissions than the portfolio-level WACI disclosures typically reported by large Dutch asset managers.

British asset manager

The British asset manager provides several tables of information related to its financed emissions: by economic sector, by asset class, and several focused data points on real estate and electricity generation. For each of the six reported sectors, the asset manager provides total financed emissions, WACI, and the corresponding PCAF data-quality scores for 2024, shown in Table A B.5 below. Although “Utilities” and “Government” produced the largest amounts of financed emissions, financing in “Materials” and “Energy” shows much higher emissions intensities relative to the level of financial exposure.

Table A B.5. Emissions reporting of a large British asset manager

Economic Sector/Asset	By value (%)	Financed emissions (tCO2e)	WACI (tCO2/mEUR revenue)	PCAF Score	Target set
Utilities	10	1 600 000	181.7	2.2	No
Energy	5	900 000	220.8	2.1	No
Materials	1	300 000	333.5	1.3	No
Industrials	6	300 000	57.5	2.3	No
Government	16	1 200 000	95.45	2.2	No
Others	62	800 000	16.1	2.3	No
Total	100	4 900 000	58.65	2.3	Yes – 50% of 2019 level
Bond	90	4 700 000	63	2.3	No
Property	9	100 000	16	2.3	No
Equity	1	-	38	2.3	No

Source: Company reporting.

The asset manager also provides information on the physical emissions intensity for its real estate and electricity generation exposure, and states that the corresponding intermediate targets have been independently verified by SBTi. Although physical intensity data is reported, it is for a limited set of assets that do not cover a large scope of the company’s assets. They are also not accompanied by estimates of financial size.

Table A B.6. Reported physical intensity metrics of a large British asset manager

Category	2019 value	2024 value	Target (2030)	Units
Electricity generation project finance portfolio	-	49	60	KgCO2e/kWh
Real estate investment portfolio	58	44	24	tCO2e/m2
Downstream leased assets	55	39	20	tCO2e/m2

Source: Company reporting.

Italian asset manager

Aside from the PAI indicators required under the SFDR, the Italian asset manager provides limited emissions and sustainability information. Rather than detailed sectoral breakdowns, it reports aggregate metrics for its investment portfolios and the share of its real estate portfolio aligned with the CRREM Paris Agreement-aligned pathway. Overall, the level of disclosure is broadly comparable to that of large Dutch asset managers operating under the same SFDR framework.

The asset manager reports aggregate financed emissions and carbon-intensity indicators for its investment portfolios and highlights reductions in emissions intensity relative to earlier reporting periods. It also reports progress against emissions-related targets and increasing alignment of real estate assets with CRREM benchmarks, including the proportion of the portfolio that follows a net-zero pathway.

Pension funds

The analysis examined the reporting of large Italian and British pension funds and found that, where metrics are disclosed, reporting covers the same indicators as Dutch pension funds, with no notable differences in scope or methodology. Supervisors may, however, receive additional sector-level exposure information bilaterally.

Insurance companies

Similar to the Netherlands, reporting on underwriting activities of insurers in the UK and Italy is generally limited. Again as in the Netherlands, insurers’ investment activities exhibit reporting practices broadly similar to those of large asset managers in the UK and Italy.

References

[3] EBA (2025), Final Report - Guidelines on the management of environmental, social and governance risks, https://www.eba.europa.eu/sites/default/files/2025-01/fb22982a-d69d-42cc-9d62-1023497ad58a/Final%20Guidelines%20on%20the%20management%20of%20ESG%20risks.pdf.

[4] EBA (2022), EBA publishes binding standards on Pillar 3 disclosures on ESG risks, https://www.eba.europa.eu/publications-and-media/press-releases/eba-publishes-binding-standards-pillar-3-disclosures-esg.

[2] OECD (2026), “Mapping climate-related metrics in the financial sector”, OECD Business and Finance Policy Papers, No. 96, OECD Publishing, Paris, https://doi.org/10.1787/e91736e8-en.

[1] OECD (2025), OECD Corporate Governance Factbook 2025, https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/10/oecd-corporate-governance-factbook-2025_56febc0d/f4f43735-en.pdf.