SS5/25 – Enhancing banks’ and insurers’ approaches to managing climate-related risks
Executive Summary
SS5/25 is the PRA's updated supervisory statement, published on 3 December 2025, replacing SS3/19 and setting enhanced expectations for banks and insurers to manage climate-related risks through governance, risk management, scenario analysis, data quality, and disclosures. It matters because it represents a step change from awareness-raising to embedding robust, proportionate practices that integrate climate risks into core prudential processes like ICAAP, ILAAP, ORSA, and capital planning, aligning with the PRA's objectives for firm safety and soundness amid evolving physical and transition risks. #
What Changed
- - Replaces SS3/19 entirely: Introduces a more mature, consolidated framework reflecting international standards (e.g., BCBS), with detailed transmission channels for climate risks across credit, market, liquidity, insurance, and operational categorie
- Governance enhancements: Emphasizes board accountability, integration into business strategy, climate risk appetite statements, and linkage to Senior Managers & Certification Regime (SM&CR) without new Senior Management Functions (SMFs); promotes cha
- Risk management integration: Requires embedding climate risks into existing frameworks with quantitative metrics/limits where material; detailed mapping of risks (e.g., physical/transition via credit/market); documentation of controls, escalation, an
- Scenario analysis: Firms must conduct climate scenario exercises capturing plausible pathways, impacts on capital/liquidity/solvency, with transparent assumptions and management challenge; longer-term for strategic planning.
- Data expectations: Critical assessment of data sources/quality (e.g., geographic/sectoral for banks, hazard/vulnerability for insurers); use proxies with documented limitations.
- Sector-specific: Banks integrate into ICAAP/ILAAP, underwriting, IFRS 9; insurers into ORSA, SCR, underwriting/pricing/reinsurance, mortality trends.
Suggested Considerations
- Conduct materiality assessment of climate risks to scope proportionality (leverage TCFD/CSRD work).
- Embed climate risks in governance: Define risk appetite, update SM&CR responsibilities, ensure board MI/challenge.
- Integrate into risk frameworks: Update risk registers, ICAAP/ILAAP/ORSA/SCR with quantitative metrics, scenarios, and controls; adjust underwriting/pricing/collateral.
- Perform climate scenario analysis: Model impacts on capital/liquidity/solvency using plausible pathways.
- Enhance data: Source/assess granular data (e.g., location/sector/hazards), document proxies/limitations.
- Document and evidence: Risk assessments, transmission channels, escalation procedures; prepare for PRA supervision.
Key Dates
Compliance Impact
Urgency: High – Effective immediately with a 6-month window (~June 2026) for gap closure, this demands significant operational uplift (e.g., data, scenarios, integration) amid PRA's shift to enforcement; non-compliance risks supervisory action, given climate risks' materiality to prudential stability and alignment with global standards.
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.
Summary
Supervisory statement 5/25