Climate action

  • The ECB has developed a climate action plan.

  • The Bundesbank procured data on companies’ climate impacts, to be used by eurosystem central banks to green their balance sheets, and to support their regulatory functions.

  • The ECB has launched a climate stress test.

Climate inaction

  • The Bundesbank has historically opposed climate action by the ECB.

  • The eurosystem’s corporate bond purchases and collateral framework have been found to have a carbon bias.

  • The Bundesbank has yet to apply climate criteria in its own investments.

How the Bundesbank stacks up

Rank Country Aggregate Score (out of 130) Grade (A+ to F) Research and Advocacy (out of 10) Monetary Policy (out of 50) Financial Policy (out of 50) Leading by Example (out of 20)
7 GermanyGermany 44 C- 10 8 23 3

Central Bank/Supervisor

Deutsche Bundesbank, European Central Bank, European Banking Authority

More info


Research & Advocacy

10 out of 10

High-impact

  • N/A

Medium-impact

  • Bundesbank is a member of NGFS

Low-impact

Monetary Policy

8 out of 50

High-impact

  • N/A

Medium-impact

  • Incorporation of climate change considerations into the collateral framework (formal commitment from ECB)

  • Incorporate climate considerations into the framework for corporate sector asset purchases (formal commitment from ECB)

Low-impact

  • ECB accepts sustainability-linked bonds as collateral

  • ECB will make environmental sustainability disclosures a condition of eligibility in collateral purchases (formal commitment)

  • ECB will make environmental sustainability disclosures a condition of eligibility in the corporate sector purchase programme (formal commitment)

  • ECB purchased green bonds under both the CSPP and the public sector purchase programme (PSPP)

Financial Policy

23 out of 50

High-impact

  • Climate-related quantitative and qualitative restrictions on banks’ portfolios (under discussion at ECB)

Medium-impact

  • Mandatory sustainability-related disclosure in the financial services sector

  • Banks are required to integrate climate and environmental risks into risk management practices

  • Economy-wide climate stress test (results available here)

  • Microprudential climate-related capital-based measures (under discussion at ECB and EBA)

  • Macroprudential climate-related capital-based measures (under discussion at ECB and EBA)

  • Requirement for banks to publish Paris-compatible transition plans (under discussion at ECB)

Low-impact

  • EBA launched a consultation to incorporate ESG risks into the governance, risk management and supervision of credit institutions and investment firms

  • EBA ran a consultation on Pillar 3 disclosures of ESG risks

  • ECB ran a public consultation on its guide on climate and environmental risks

  • ECB will develop new statistical indicators to assess the carbon footprint of banks, as well as their exposures to climate-related physical risks (formal commitment)

  • ECB will review how credit ratings reflect climate risk (formal commitment)

Leading by Example

3 out of 20

High-impact

  • N/A

Medium-impact

  • N/A

Low-impact

What steps are missing in the Bundesbank toolbox to address climate risk?

Civil society expects the bank to do the following:

  • Along with the rest of the eurosystem, fully decarbonise its collateral framework and asset purchases.

  • Follow the Banque de France’s example in committing to phase out its fossil fuel investments.

  • Adjust its refinancing operations in line with the 1.5°C targets of the Paris Agreement.

  • Ensure its responsible investment charter is fully aligned with the Paris goals.

  • Support development and implementation of macroprudential measures to align financial flows with the Paris agreement.