2024-12-12
Added · Updated
The Swiss Financial Market Supervisory Authority (FINMA) issued Circular 2026/1 to mandate that banks and insurers integrate the management of climate and other nature-related financial risks into their governance, risk identification, and internal control systems. The regulation requires institutions to conduct materiality assessments and scenario analyses, while imposing specific operational, credit, market, and liquidity risk management obligations tailored to their business models. These requirements are phased in, with Category 1 and 2 institutions needing to address climate risks by January 2026 and full implementation required for all covered entities by January 2028.
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Circular 2026/1
Nature-related financial risks
Management of climate- and other nature-related financial risks Reference: FINMA Circ. 26/1 “Nature-related financial risks” Date: 12 December 2024 Entry into force: 1 January 2026 Legal framework: FINMASA Articles 7 para. 1 let. b, 29 para. 1 BA Articles 3 para. 2 let. a, 3f BO Article 12 paras. 2, 3, 4 ISA Articles 22 para. 1, 27, 67 para. 3, 75 para. 3 ISO Articles 96-98a, 191 para. 1, 195 para. 1, 196, 204 Addressees (indicative) BA ISA FinIA FinMIA CISA AMLA Other Banks Financial groups and congl. Persons under Article 1b BA Other intermediaries Insurers Insurance groups and congl. Intermediaries Portfolio managers Trustees Managers of collective assets Fund management companies Investment firms (proprietarian trading) Investment firms (non propriet. trading) Trading venues Central counterparties Central securities depositories Trade repositories Payment systems Participants SICAVs Limited partnerships for CISs SICAFs Custodian banks Representatives of foreign CISs Other intermediaries SROs SRO-supervised institutions Audit firms Rating agencies X
Index
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I. Subject matter
II. Scope of application and proportionality
III. Definition of terms
IV. Common provisions
A. Governance
B. Risk identification, materiality assessment and scenario analyses
C. Risk management
D. Stress tests
V. Provisions for banks
A. Credit risk management
B. Market risk management
C. Liquidity risk management
D. Managing operational risks and ensuring operational resilience E. Management of compliance, legal and reputational risks
VI. Provisions for insurers
A. Insurance activities
B. Management of market, credit and liquidity risks
C. Management of operational risks as well as compliance, legal and
reputational risks
D. Own Risk and Solvency Assessment
E. Responsible actuary
VII. Transitional provisions
Margin no.
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Margin no.
2-8
9-13
14-34
14-15
16-27
28-32
33-34
35-49
35-41
42-43
45-48
50-63
50-54
55-59
60-61
64-66
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I. Subject matter
With regard to climate- and other nature-related financial risks, this circular sets out the provisions for risk management and its internal documentation, as well as for the internal control system in accordance with Articles 3 para. 2 let. a and 3f of the Banking Act of 8 November 1934 (BA; SR 952.0) and Article 12 paras. 2–4 of the Banking Ordinance of 30 April 2014 (BO; SR 952.02) as well as in accordance with Articles 22 para. 1, 27, 67 para. 3, and 75 para. 3 of the Insurance Supervision Act of 17 December 2004 (ISA; SR 961.01) and Articles 96–98a, 191 para. 1, 195 para. 1, 196 and 204 of the Insurance Supervision Ordinance of 9 November 2005 (ISO; SR 961.011).
II. Scope of application and proportionality
This circular applies to:
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III. Definition of terms
Nature-related financial risks are defined as the short-, medium- and long-term potential for direct or indirect negative financial effects on the institution resulting from its exposure to climate and other nature risks. Nature-related financial risks include climate-related financial risks and other nature-related financial risks. Nature risks (including climate risks) are risk drivers that can be reflected in existing risk types at the institutions through various transmission channels as nature-related financial risks, in particular in credit risks (including counterparty credit risks), market risks, liquidity risks, operational risks, insurance risks, business risks, compliance, legal and reputational risks. Nature risks can be categorised as follows:
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FINMA Circular 2017/1 “Corporate governance – banks” and 2017/2 “Corporate governance – insurers”. The bodies, functions and units listed in margin no. 14 shall possess sufficient expertise and experience in relation to nature-related financial risks and how to deal with them to be able to fulfil their defined role. B. Risk identification, materiality assessment and scenario analyses The institution shall periodically identify the nature-related financial risks that could affect it and assesses their financial materiality for its risk profile. The institution shall also take into account the strategic impact of nature risks as well as potential legal and reputational risks. The design of the risk identification and materiality assessment shall take particular account, where relevant, of:
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Justifications must be provided for any missing categorisations or categorisations that deviate due to the specific circumstances of the institution. The frequency of the risk identification and materiality assessment shall depend on the significance of nature-related financial risks for the institution’s risk profile and on new findings and changes at the institution itself or in the institution’s environment that may have a material impact on its exposure to nature-related financial risks.6 The frequency of quantitative scenario analyses may deviate in justified cases.
C. Risk management
Institutions shall integrate the management and monitoring of the nature-related financial risks assessed as material and the reporting of these risks appropriately into their institution-wide risk management and internal control system7 – taking into account the time horizons of the risks. This shall also include the consideration of possible concentration risks caused by nature risks, e.g. through concentrations of business activities or portfolios in certain sectors, industries or regions. Based on its risk tolerance for nature-related financial risks, the institution shall define suitable risk indicators with warning thresholds and limits, where possible and appropriate, in order to monitor its nature-related financial risks that are assessed as material. It shall also include forward-looking risk indicators. The institution shall integrate the monitoring of warning thresholds and limits into its existing internal monitoring and reporting processes. The institution shall periodically assess and determine its methods and information requirements for the management of its material nature-related financial risks and adapt its information sources, methods and processes accordingly. It shall take into account relevant national and international developments. The institution shall regularly assess whether its sustainability-related public statements are in line with its business strategy, its risk tolerance, its risk management and its statutory obligations.8 D. Stress tests Category 1 and 2 banks with material nature-related financial risks shall gradually integrate these into their stress tests and their internal assessment of the adequacy of financial resources. 6 For example, changes to statutory provisions, significant changes in the portfolio structure/size or relevant adjustments to the business model, materialisation of relevant nature risks, new scientific findings. In addition to the definition of tasks, competencies and responsibilities in accordance with margin no. 14, this shall mean the appropriate implementation of control activities in the business or organisational units concerned, as well as by the independent control bodies in accordance with FINMA Circular 17/1 and control functions in accordance with FINMA Circular 17/2. 8 For example, transition plans that are consistent with the Swiss climate targets for net-zero emissions by 2050, targets for reducing CO2 emissions or for directing financial flows towards sustainable activities or an effective climate contribution by the financial centre.
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Insurers with material nature-related financial risks shall take these into account as part of the Own Risk and Solvency Assessment (ORSA) (margin no. 62).
V. Provisions for banks
A. Credit risk management
Institutions with material nature-related credit or counterparty credit risks shall take these into account over the entire life cycle of a position exposed to such a credit or counterparty credit risk. This shall include conducting due diligence before accepting new clients and the ongoing monitoring of their risk profiles. To control or reduce material nature-related credit or counterparty risks, the institutions shall use instruments that are appropriate to their size, complexity and structure as well as their risk profile and business model. These shall include, where possible and appropriate:
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D. Managing operational risks and ensuring operational resilience Institutions with material nature-related operational risks shall ensure that their management of operational risks in accordance with FINMA Circular 2023/1 “Operational risks and resilience – banks” adequately takes these risks into account. Material naturerelated operational risks are to be taken into account in the risk and control assessments for operational risks, as well as in other components of operational risk management, where relevant and logically coherent. If material internal losses result from nature-related operational risks, this must be clearly disclosed in the internal reporting in accordance with margin no. 39 of FINMA Circ. 23/1. Institutions in categories 1–3 that systematically collect and analyse internal loss data and relevant external events relating to operational risks in accordance with margin no. 34 of FINMA Circ. 23/1 shall be in a position to clearly disclose losses and events relating to nature risks in the corresponding reports. Material nature-related operational risks that are relevant to the provision of a critical function of the institution shall be documented accordingly (see margin no. 108 of FINMA Circ. 23/1) and taken into account in ensuring the operational resilience of the institution. They shall also be taken into account when creating or updating corresponding business continuity plans and disaster recovery plans. E. Management of compliance, legal and reputational risks Institutions with material nature-related compliance, legal or reputational risks shall assess their impact, including the possibility of resulting financial losses. They shall also ensure that the handling of these risks is integrated into the relevant processes and controls.
VI. Provisions for insurers
A. Insurance activities
Institutions with material nature-related financial risks in their insurance activities shall integrate these risks into the relevant processes, guidelines and controls, taking into account their time horizons. The following areas in particular must be taken into account:
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B. Management of market, credit and liquidity risks Institutions shall take nature risks into account in the relevant risk management processes, guidelines and controls if these risks could have a direct or indirect material impact on the following areas in particular:
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All institutions shall implement the circular in full by 1 January 2028. 66
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Source: Swiss Financial Market Supervisory Authority — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works