Response to consultation on Guidelines on ESG scenario analysis

Question 1: Do you have any comments on the interplay between these Guidelines and the Guidelines on the management of ESG risks?

Please refer to the attached response document for detailed comments.

Question 2: Do you have comments on the proposed definition of scenario analysis and its various uses as presented in Figure 1?

Please refer to the attached response document for detailed comments.

Question 3: Do you have comments on the proposed distinction made between short-term scenario analysis (CST) and longer-term scenario analysis (CRA) as illustrated in Figure 3?

Please refer to the attached response document for detailed comments.

Question 4: Do you have any comments on the interplay between these Guidelines and the Guidelines on institution’s stress testing?

Please refer to the attached response document for detailed comments.

Question 5: Do you have comments on the Climate Scenario Analysis framework as illustrated in Figure 4?

Please refer to the attached response document for detailed comments.

Question 6: While respecting the definitions provided in other parts of the regulation, is there any concept/s used in these guidelines that it would be useful to include in an annexed glossary?

Please refer to the attached response document for detailed comments.

Question 7: Do you have comments on section 4.1 Purpose and governance?

Please refer to the attached response document for detailed comments.

Question 8: Do you agree that the proposed proportionality approach is commensurate with both the maturity of the topic and the size, nature and complexity of the institution’ s activities?

N/A

Question 9: Do you agree with the proposed references to organisations in paragraph 28? Would you suggest alternative or complementary references?

Please refer to the attached response document for detailed comments.

Question 10: Do you have additional comments on section 5.1 Setting climate scenarios?

Please refer to the attached response document for detailed comments.

Question 11: Do you have comments on the description of the climate transmission channels?

Please refer to the attached response document for detailed comments.

Question 12: Do you have comments on climate stress test (CST) tool and its use to test an institution’s financial resilience?

Please refer to the attached response document for detailed comments.

Question 13: Do you have comments on the Climate Resilience Analysis (CRA) tool and its use to challenge an institution’s business model resilience?

Please refer to the attached response document for detailed comments.

Question 14: Do you have any additional comments on the draft Guidelines on ESG Scenario Analysis?

N/A

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