EBA Guidelines on environmental scenario analysis – applicable from 1 January 2027

On 5 November 2025, the European Banking Authority (EBA) published Guidelines (EBA/GL/2025/04) on environmental scenario analysis.

The Financial Supervisory Authority has confirmed that it will comply the Guidelines.

In accordance with Article 16(3) of the EBA Regulation¹, financial institutions shall make every effort to comply with EBA Guidelines.

Subject matter

The Guidelines specify the criteria for setting the scenarios that institutions should use to test their resilience to long-term negative impacts of environmental factors, in particular climate-related factors, in accordance with Article 87a(3) and 87a(5), point (d) of Directive 2013/36/EU. In addition, the Guidelines specify how climate-related risk factors are to be integrated into stress testing and set out criteria for scenario analysis used to test institution’s resilience to short-term negative impacts of environmental factors.

The Guidelines complement the EBA Guidelines on the management of ESG risks (EBA/GL/2025/01) and the EBA Guidelines on institutions’ stress testing (EBA/GL/2018/04). Furthermore, they specify how institutions using the Internal Ratings-Based (IRB) Approach should define and use stress test scenarios that include environmental risk drivers, in particular climate-related physical and transition risks, in credit risk internal stress testing in order to meet the requirements laid down in Article 177(2a) of Regulation (EU) No 575/2013.

Date of application

The Guidelines will apply from 1 January 2027.

For further information, please contact

Deni Seitz, Senior Specialist, telephone +358 9 183 5415 or deni.seitz(at)fiva.fi

Appendix

EBA Guidelines

See also

Guidelines of the European Supervisory Authorities

¹Regulation (EU) No 1093/2010 establishing the EBA