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Climate-related risks are now a part of fit and proper assessments


Published: 02 March 2021

Financial institutions must increasingly factor in the risks related to climate change and the transition to a carbon-neutral economy. We have therefore integrated these topics into fit and proper assessments for banks, insurers and pension funds.

  • Climate-related and environmental risks will feature more prominently in our assessment interviews. We may ask a candidate about their knowledge of such risks, relevant legislation and their impact on the institution.
  • The institution must include in the assessment file it submits information on the candidate's knowledge and experience with regard to such risks. It may do so while describing its appointment considerations and decision, or include this in its notes to the modified suitability matrix, or both. See Fit and proper assessments


In assessing fitness, we use the criteria listed under A through E in the Policy Rule on Fitness 2012. For example, we expect a proposed management or supervisory board member or other policymaker or co-policymaker to be able, with respect to climate-related and environmental risks, to:

  • be able to define these risks
  • be aware of relevant laws and regulations and of reporting obligations
  • be able to identify, monitor and manage them
  • know who is responsible for managing them in the institution
  • understand their impact within the institution's specific context, and to be able to cite examples
  • be able to formulate a strategy and policies to tackle them
  • take responsibility for ensuring their adequate management
  • in the case of supervisory board members: to monitor their adequate management
  • have sufficient relevant competencies, such as a helicopter view, leadership, autonomy, sensitivity to their environment, strategic guidance and sense of responsibility.

Proportional application

In our assessment we take into account the candidate's proposed position, the institution's nature, size, complexity and risk profile, and the composition and functioning of the board as as whole. We expect a management board member responsible for risk management to have more in-depth knowledge, experience and competencies in the areas listed above than a board member with more general areas of responsibility.

Further information

If you wish to know more about how we address climate-related and environmental risks as part of our fit and proper assessments, feel free to contact our Expert Centre on Fit & Proper Assessments by email at toetsing.expertisecentrum@dnb.nl.