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From ambition to execution: transition plans for financial institutions


A practical EY approach for defining strategy, accelerating action and enabling net-zero transformation across financial institutions.

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In brief

  • Ten years after the Paris Agreement, financial institutions are increasingly navigating the question of how their business models, portfolios and client relationships can support the transition to a net-zero economy.
  • A transition plan is not only a disclosure output. It is a management framework that connects climate ambition with portfolio steering, client engagement, financial planning, governance and measurable progress.
  • EY supports financial institutions through a pragmatic net-zero transition plan framework built around three phases: define strategy, accelerate action and enable transformation.

Ten years after the Paris Agreement, the global economy is entering a decisive phase in its transition to net zero. More than 190 countries have adopted net-zero pledges, and financial institutions are increasingly expected to explain how their financing, investment and insurance activities align with long-term climate objectives. The focus is shifting from commitments alone to evidence of how those commitments are reflected in strategy, risk management and portfolio-related decisions.

For a financial institution, not developing a transition plan does not simply mean foregoing an active role in reducing climate impact. It also means missing the opportunity to channel capital toward the real-economy transition, while remaining less equipped to identify and manage emerging transition and physical risks.

Swiss Re Institute’s analysis1 shows that extreme events are already financially material, with USD 42 billion of insured natural catastrophe losses in the first half of 2026. Heatwaves, droughts and wildfire conditions can affect financial institutions through claims, collateral values, borrower disruption and rising credit, market and operational risk.

A transition plan is therefore far more than an informational disclosure framework. It is a strategic management tool that can guide interventions across governance, risk management, product design, client engagement and capital allocation. Rather than being a compliance exercise, it can become a roadmap for resilience and competitiveness in a decarbonizing economy.

In this context, transition plans should create a bridge between ambition and execution. They should connect climate objectives with sector and portfolio strategies, product development, client engagement, financial planning, governance and performance management, creating a practical line of sight from targets to implementation.

In a global economy shifting toward net zero, where does your financial institution stand?

What makes a transition plan credible?

While climate transition plan frameworks differ in scope and emphasis, they are converging around a common set of building blocks. The first is scope and materiality. For a financial institution, scope should clarify which portfolios, geographies, business lines, asset classes and emissions categories are covered, including own operations and, most importantly, financed, facilitated or insured emissions due to their materiality.

 

Materiality should explain which climate-related impacts, risks and opportunities the plan is designed to address. This includes greenhouse gas emissions impacts, transition risks linked to policy, technology, market and macroeconomic developments, as well as physical risks linked to climate-related hazards affecting real assets and counterparties across locations. A credible plan should recognize that the frequency, intensity and financial relevance of physical hazards vary by geography, asset type and available adaptation options.

 

Credibility also requires clear strategic ambition. The plan should define objectives and priorities, explain how they align with relevant national or international commitments and requirements, and set out the assumptions on which the plan depends. These assumptions may include the pace of economic decarbonization, especially sector pathways.

34%
34%
of financial institutions in Europe have SBTi-validated targets.

This 34% is a positive sign. However, target validation should be seen as a starting point, not the end state: credibility also depends on whether targets are translated into governance, portfolio steering, client engagement and measurable progress.

Governance is the foundation for implementation. A transition plan needs board oversight, clear management responsibilities, defined roles across functions, adequate capabilities, a culture that supports delivery and incentives that are consistent with the plan’s objectives.

Once governance is in place, the plan should translate ambition into current and anticipated actions. These actions may affect assets, products, services, policies, client engagement, portfolio steering and financial planning. For financial institutions, stakeholder engagement is central because financed clients, investees, asset owners, policyholders, industry initiatives and public-sector stakeholders shape the feasibility of the transition.

43%
43%
of financial institutions in Europe do not disclose the intention to phase out investing in oil and gas.

This is where the gap between ambition and execution becomes visible. While target-setting is gaining traction, 43% of European financial institutions still do not disclose an intention to phase out investment in oil and gas, suggesting that sector-level transition choices remain one of the most challenging areas of market practice.

Finally, the plan must be measurable and comparable. It should include indicators and targets for own operations, down-stream emissions (especially financed and insured emissions), whether absolute or intensity-based and, where relevant, by asset type. Carbon credits should be considered only for residual emissions that cannot be abated, with transparent disclosure of their purpose and quantity. Progress should be reported regularly using recognized international standards to support comparability.

20%
20%
of financial institutions in Europe do not disclose progress on transition plans and do not indicate when to adopt one.

As market expectations evolve, this lack of visibility may become increasingly difficult to sustain, particularly as stakeholders look for evidence of governance, implementation and measurable progress.

EY’s climate transition plan framework

Understanding how to build transition plans requires a structured but flexible approach. EY’s approach helps financial institutions move through three connected phases: define strategy, accelerate action and enable transformation. The framework recognizes that there is no single starting point. Each institution has a different portfolio composition, sector and geographic exposure, business model, maturity level and regulatory context.

EY phasePurposeKey questions

Define strategy
Clarify the ambition, material exposures and business case for action.How is the world aligning toward net zero? What does this mean for the portfolio? Which sectors, geographies and business lines are most material in terms of risks and opportunities? What objectives, priorities and interim targets should guide the plan?
Accelerate actionTranslate ambition into business, portfolio and client-facing levers.Which products, policies, portfolio steering actions and engagement strategies are needed? How will actions affect assets, services and financial planning? How will counterparties’ transition plans be assessed?
Enable transformationEmbed the plan into the operating model and make delivery measurable.Who owns delivery? Which governance, risk, data, technology, skills, controls and reporting processes are required? How will progress be monitored and updated?

Define strategy: start with materiality

A practical starting point is the materiality or double materiality assessment. This exercise is useful not only for reporting requirements such as CSRD and ISSB, but also because it identifies whether and how climate change could create positive or negative impacts for the financial institution, and how the institution may itself create impacts through its financing, investment or insurance activities.

A well-structured materiality assessment helps identify which products, services, sectors and geographies are most affected and whether the relevant impacts, risks and opportunities are limited to own operations or extend across the value chain. If conducted holistically across environmental, social and governance matters, it can also reveal interdependencies between climate, biodiversity, water management and other sustainability topics.

Climate scenario analysis is also becoming a core expectation across many regulatory and supervisory landscapes and an important tool for managing climate-related financial risks. By testing transition and physical risk pathways, institutions can identify material exposures across sectors, geographies and time horizons. These exercises are typically scenario-contingent: they assess outcomes conditionally on a given scenario, without necessarily assigning probabilities to each scenario.

A transition plan can therefore do more than reduce negative climate impacts, mitigate risks and capture climate-related opportunities. It can also provide an integrated framework for addressing interconnected sustainability topics that might otherwise be managed through separate workstreams.

Accelerate action: move from targets to implementation

The need for action is reinforced by current market practice. Many institutions disclose progress against emission-reduction targets, but fewer disclose the key elements that make a plan operational, such as financial resources, implementation levers and granular portfolio objectives. This creates uncertainty about feasibility and increases greenwashing risk.

6.2
6.2
Average number of levers disclosed per financial institution in Europe.

Financial institutions do not need to start from zero. Recent guidance, standards and market practices provide useful reference points. However, these documents serve different purposes and should be used accordingly: disclosure frameworks define what should be reported, validation frameworks assess whether targets and commitments are credible, and guidance frameworks support the design and implementation of the plan.

For financial institutions, disclosure and validation frameworks are relevant not only internally but also for assessing counterparties. Because the climate impact and risk profile of banks, insurers and asset managers is largely driven by the activities they finance, invest in or insure, counterparty-level information is essential. A transition strategy should therefore integrate the assessment of clients’ and investees’ transition plans into governance, risk management, engagement and capital allocation.

Enable transformation: make the plan governable and repeatable

A credible transition plan must be embedded into the operating model. This includes governance, risk management, data, technology, controls, capabilities, engagement models and reporting. The objective is to make the plan decision-useful, repeatable and capable of being updated as policies, markets, technologies and client strategies evolve.

The plan should also be anchored in roles and responsibilities. Board oversight, management accountability, cross-functional collaboration, training and incentives are essential to ensure that transition planning does not remain confined to the sustainability function but informs strategy, risk, business development and client dialogue.

The following pillars translate the three EY phases into concrete building blocks for financial institutions.

EY phasePractical pillarWhat the plan should cover

Foundational

1. Governance2
The governance structure required to guide and oversee the development of the transition plan, ensuring that the right decision-making, supervision and ownership are in place from the outset to support the definition of the strategic ambition and implementation approach.
Define strategy2. Materiality and strategic ambitionPortfolio and value-chain scope, direct and indirect emissions where material, transition and physical risks, opportunities, objectives, priorities, assumptions, external commitments, trade-offs, scenario analysis, timelines and interim targets.
Accelerate action3. Business operations and financial planningCurrent and anticipated actions, asset impacts, product and service changes, portfolio steering, policies, contribution of actions to the overall ambition, funding needs and financial planning.
 4. Stakeholder engagementEngagement with borrowers, investees, asset owners, policyholders, clients, industry initiatives and public-sector stakeholders, including the assessment of counterparties’ transition plans and ESG information.
Enable transformation5. Indicators, targets and reportingOperational metrics, financial metrics, absolute or intensity-based GHG metrics by asset type where relevant, engagement metrics, transparent carbon credit use for residual emissions and regular reporting using recognized standards.
 6. Culture and accountabilityCapabilities, culture, training, incentives, remuneration and accountability mechanisms aligned with delivery of the plan and embedded into the operating model.

From framework to practice: selected transformation journeys

Recent client work shows how the framework can be translated into practical transformation journeys. 

Case study 1: using materiality and strategic ambition to prioritize risks for quantification

Starting point
A financial institution needed to move from a broad universe of potential climate-related risks to a more focused view of the risks that could materially affect its portfolio and strategic ambition. Given the variety of physical and transition risk drivers, transmission channels, instrument types and geographic exposures, the institution required a pragmatic first screening layer before moving into detailed quantification or scenario analysis.
EY supportEY supported the institution in developing a qualitative, top-down assessment to prioritize climate-related risks. The work started from a long list of potential risks, informed by internal risk taxonomies, regulatory expectations and subject-matter expertise. Each risk was assessed against aggregate criteria such as magnitude, likelihood and potential financial impact, considering the institution’s portfolio composition, including relevant asset classes, instrument types and geographic exposures. The results were translated into ratings and visualized through heatmaps to identify which risks were potentially material.
ResultThe assessment provided a structured and pragmatic basis for deciding which climate-related risks should be further quantified, reflected in scenario analysis or integrated into the transition plan. By using qualitative materiality as a first screening layer, the institution was able to bridge broad risk identification with focused quantitative assessment and allocate analytical effort to the risks most relevant to its portfolio and strategic priorities.
Case study 2: using indicators, targets and reporting to make climate risks measurable

Starting point
A financial institution had already identified a set of potentially material climate-related risks but needed to translate them into measurable exposures, financial impacts and monitoring metrics. The institution required a structured approach to understand how these risks could affect its portfolio, how they should be monitored over time and how they could be linked to risk appetite, portfolio steering and management reporting.
EY supportEY supported the institution in defining decision-useful indicators, targets and reporting metrics aligned with the relevant risks, asset classes, geographies and time horizons to comply to FINMA’s regulatory requirements from Circular 26/1 on nature-related financial risks. This included identifying appropriate data sources and reference frameworks, such as NGFS scenarios, as well as market and scientific sources including MSCI, Bloomberg, IPCC and IEA. EY also supported the development of an assessment logic to flag investments exposed to risks previously identified as potentially material and aggregate the affected share of the portfolio. Where relevant, scenario-contingent transition and physical risks were translated into effects on financial risk factors such as probability of default, loss given default, market value or loan-to-value ratios, for example by mapping internal sector and geography classifications, such as NACE, to NGFS classifications.
ResultThe approach enabled the institution to move from qualitative risk identification to measurable climate risk monitoring. Targets anchored in risk appetite helped identify problematic exposures, concentration risks and potential misalignment with the institution’s transition ambition. The resulting metrics and reporting outputs provided a practical basis for management reporting and informed portfolio steering actions, including client engagement, exposure reduction, rebalancing or allocation optimization, while considering return, diversification, liquidity and other financial performance constraints.
Case study 3: Creation of an “ESG risk plan”

Starting point
As regulatory expectations on ESG risk management continue to evolve across Europe, banks are increasingly expected to translate climate and environmental risk considerations into structured planning, governance and steering processes. A banking association wanted to support its member institutions by developing a practical ESG risk plan template, including illustrative text blocks and guidance that banks could adapt to their own business model, risk profile and ESG materiality.
EY supportEY supported the development of the template by defining a clear and practical outline for the ESG risk plan, covering key elements such as strategic ambition, governance, metrics and targets, monitoring and integration into risk management practices. The template was complemented by example text blocks and practical guidance, developed through workshops and interviews with banks to reflect different levels of maturity, methodologies and available data.
ResultThe final output provides member banks with a structured starting point to develop their own ESG risk plans. By adapting the template to their specific ESG materiality, portfolio characteristics and internal risk management approach, banks can use it as a practical tool to strengthen ESG risk steering and support regulatory readiness.

What good looks like

A strong transition plan creates a clear line of sight from ambition to action. It explains what the financial institution is trying to achieve, why the priorities are material, how the plan changes business practices and how progress will be monitored over time.

For financial institutions, the most credible plans connect internal strategy with real-economy transition. This requires engagement with borrowers, investees, asset owners, policyholders and clients to understand their transition readiness, financing needs and constraints.

The result should be a plan that is strategic, measurable, financially grounded and embedded into the operating model. It should help the institution make better decisions today while retaining the flexibility to evolve with regulation, technology, markets and client strategies.

Financial institutions that treat transition plans as strategic management tools, rather than only as reporting requirements, will be better positioned to perform in the coming economy.

How EY can support

EY can support financial institutions across the full transition planning journey, from defining strategic ambition and portfolio scope to designing implementation levers, governance, KPIs and reporting processes.

Our approach combines climate expertise with financial services, risk management, regulatory, data and transformation capabilities. This helps institutions move from fragmented initiatives to an integrated transition plan that is practical, decision-useful and aligned with the realities of their portfolios and operating models.

EY State of Play Report 2026

Banks are advancing their transition plans, but true strategic integration remains a work in progress. Discover the latest trends, progress areas and key challenges shaping the banking sector.

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Summary

Transition planning is becoming a business imperative for financial institutions navigating an evolving climate, regulatory and market landscape. Success depends on turning long-term ambitions into practical decisions across portfolios, clients, governance and risk management. Institutions that integrate transition planning into core business processes can strengthen resilience, identify new opportunities and better position themselves for a low-carbon economy while maintaining flexibility as expectations continue to evolve.

Acknowledgement

The authors would like to thank Mirko Trentin, Financial Services Climate Change and Sustainability, as well as Jean-Noël Ardouin, Alan Roncoroni and Tim Bremer, Financial Services Risk Consulting, for their valuable contributions and support in the development of this article.



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