2026-05-20
The Danish Financial Supervisory Authority issued this guidance following regulatory dialogues to address heightened geopolitical credit risks, requiring credit institutions to strengthen risk management through enhanced monitoring, scenario analysis, and stress testing. The regulator mandates a concentrated focus on export-dependent sectors and global supply chains exposed to tensions in China, the US, and the Middle East, while noting that smaller institutions must compensate for limited analytical capacity through qualitative assessments and direct customer engagement. Additionally, the authority requires that loan loss provisions be supplemented with substantial management judgments to capture structural risk shifts and prolonged conflict scenarios, as automated modeling cannot fully reflect the current geopolitical landscape.
Sector News 08-04-2026
The Danish Financial Supervisory Authority (Finanstilsynet) held discussions in late 2025 and throughout 2026 with the largest credit institutions regarding their management of geopolitical credit risks. The discussed topics are generally relevant to Danish commercial and mortgage credit institutions, and we therefore share our considerations and conclusions here. The dialogue follows up on discussions with the institutions in April 2025 on how the economic and political developments in the United States affect credit risks and loan loss provisions. Those previous discussions led to a published note in June 2025, which indicated that developments in the US have increased credit risk and the need for provisions. The observations from the most recent dialogue with the institutions are described in the following sections.
Geopolitical unrest has become an important element in the risk management of many commercial enterprises and institutions.
Institutions are particularly focusing on sectors and companies dependent on exports, global supply chains, and stable energy and commodity prices. In practice, this covers mainly companies with activities in or significant dependence on China, the US, and the Middle East, most recently with a special focus on the consequences of the US and Israel's attack on Iran.
The largest institutions have strengthened their risk management through increased monitoring and regular scenario analyses and stress tests, but they also face challenges with the data foundation. Smaller institutions lack the same analytical capacity but must conduct more qualitative assessments and engage in dialogue with relevant customers.
Dialogue with individual customers is important to understand how customers are affected by geopolitical risks.
Customers have generally shown considerable adaptability and caution, but some are severely affected by geopolitical developments.
Management judgments remain significantly necessary because provision models cannot capture the full impact of the changed risk picture. Provisions must, among other things, account for the institution's assessment of the probability and effects of a prolonged and intense Iran conflict despite the recently concluded ceasefire.
Geopolitical unrest and its significance for credit risk have grown in recent years. Institutions highlight uncertainty regarding energy and commodity prices, disruptions to global supply chains, uncertainty about international trade terms, new or expanded tariffs and sanctions, and interventions citing national security as significant risk factors.
Institutions assess that geopolitical risks are increasingly taking on a structural character. Whereas geopolitical tensions were previously often viewed as temporary disruptions, they are now considered a more lasting and integrated part of the global risk landscape. This implies that many commercial customers have adjusted their business operations based on the consideration that geopolitical risks are here to stay.
Similarly, institutions have restructured their risk management to account for the new situation.
Institutions have strengthened monitoring of credit risks related to geopolitical unrest, with a particular focus on sectors and companies dependent on exports, global supply chains, and stable energy and commodity prices.
Institutions are particularly focusing on companies with activities in or significant dependence on China, the US, and the Middle East, where geopolitics can affect companies' supply security, profitability, and investment decisions. They make the following considerations, among others:
The increased geopolitical risks have not led institutions to systematically change credit access for commercial customers or significantly tighten credit terms. A prolonged and intense Iran conflict, despite the recently concluded ceasefire, will affect a number of particularly vulnerable companies and the broader economy, thereby necessitating tightening. This is particularly relevant if it has long-lasting significant effects on oil and gas extraction infrastructure.
In light of geopolitical unrest, the largest institutions have strengthened their risk management through increased monitoring and regular scenario analyses and stress tests. The work is based on updated macroeconomic scenarios, including trade conflicts, sanctions, disruptions to trade routes, and energy crises. The analyses specifically target sectors and markets with particular exposure, but also consider how other customers may be affected by changes in consumer and business confidence, GDP, interest rates, inflation, etc. However, there are differences in the scope and frequency of the largest institutions' analyses.
Institutions other than the largest typically do not have the same need or opportunity to conduct extensive analyses and must therefore work more with qualitative assessments and dialogue with relevant customers.
Even the largest institutions continue to face limitations in their data foundation, particularly regarding customers' indirect exposures in value chains and dependence on sub-suppliers. Many companies thus operate across multiple countries and sectors, and their value chains can involve a large number of suppliers, sub-suppliers, and logistics partners. Value chains are also not static – companies relocate production, switch suppliers, and change logistics to adjust costs or react to market conditions. This makes it difficult to gain a comprehensive overview of where exposures actually lie, which is sufficient to assess credit risk. To compensate for this, institutions use, among other things, proxy indicators and supplementary qualitative analyses. They are also strengthening data collection and recording.
Conversely, institutions can easily monitor their allocation of increased credit facilities to each customer and customers' utilization of their facilities. Increased facilities and higher utilization can reflect elevated risk, but often do not.
Regardless of the challenges described above, data on individual customers and their utilization of credit facilities, combined with analyses and stress tests, provide a solid foundation for institutions' dialogue with customers. Through this dialogue, institutions gain a clearer picture of how individual customers are affected by geopolitical risks and how customers are managing those risks.
Institutions assess that customers have generally shown adaptability and caution in the face of geopolitical unrest. Many companies have improved their liquidity by postponing or reducing major investments and acquisitions. Others have actively worked to geographically diversify production, suppliers, and exports to reduce dependence on specific vulnerable regions. This includes, for example, supplementing production in China with activities in Europe or Southeast Asia, and partially replacing US sales with sales in other countries. Some customers have also reduced their financial risks by hedging them with derivatives, etc.
Experiences from previous crises, including COVID-19, Russia's full-scale invasion of Ukraine, the energy crisis, and periods of significant interest rate hikes and high inflation, have strengthened companies' risk awareness, adaptability, and resilience.
Despite improved risk management, some commercial customers are also severely affected by geopolitical developments. This may be because their business model is particularly exposed to the negative developments, or because they have not responded appropriately to the changes. Some of these customers have caused institutions significant losses, while other customer relationships involve considerable loss risk. This applies, among other things, to certain companies in renewable energy production that have been hit by changes in energy prices, inflation, and interest rates, or by overly optimistic expectations.
Institutions continuously monitor how provisions on loans, etc., should be adjusted in light of geopolitical developments. It remains the case that management judgments are significantly required because provision models cannot capture all relevant aspects of the changed risk picture.
Provisions must, among other things, account for the institution's assessment of the probability of:
Geopolitical unrest places new demands on credit institutions and their risk management. Both monitoring, scenario analyses, and dialogue with customers are central tools that require continuous adjustment. Provisions must be supplemented with management judgments. Institutions must therefore remain flexible and attentive to developments to ensure robust management of these complex risks.
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