Climate risk disclosure for banks: RBI, IFRS S2, TCFD and MAS in 2026
Climate risk disclosure for banks follows the four-pillar structure that began with TCFD and now sits in IFRS S2: governance, strategy, risk management, and metrics and targets, including financed emissions. In India, the RBI's climate-related financial risk disclosure framework was released in draft in February 2024 and, as of October 2026, has not been issued in final form. In Singapore, listed banks report under ISSB-based rules and MAS has added transition planning guidelines that take effect in 2027.
The four pillars of climate risk disclosure
Almost every framework for banks uses the same skeleton:
- Governance: how the board and management oversee climate-related risks and opportunities.
- Strategy: the risks and opportunities identified, their effect on the business model and lending strategy, transition plans and the resilience of the strategy under climate scenarios.
- Risk management: how physical and transition risks are identified, assessed and integrated into credit, market and operational risk processes.
- Metrics and targets: the bank's own Scope 1, 2 and 3 emissions — with financed emissions as the dominant part of Scope 3 — exposures to carbon-related sectors, and progress against targets.
Getting the first three pillars right is largely a governance task. The fourth is a data task, and it is where most banks need the longest lead time.
TCFD for banks: where it stands
The TCFD published its recommendations in 2017 and supplementary guidance for banks, insurers and asset managers. It disbanded in October 2023 after the ISSB issued IFRS S1 and S2, and the IFRS Foundation took over monitoring of company climate disclosures. "TCFD-aligned" reporting remains common, but new regulation now points to IFRS S2 or to national standards built on it.
IFRS S2 for banks
IFRS S2 incorporates the TCFD pillars and adds specific requirements for financial institutions. Entities in commercial banking, asset management and insurance must disclose information about financed emissions. For a commercial bank this includes absolute gross financed emissions split by Scope 1, 2 and 3 of counterparties, broken down by industry and asset class, gross exposure to each industry, the share of exposure included in the calculation, and the methodology used.
The December 2025 amendments
On 11 December 2025 the ISSB issued targeted amendments to IFRS S2, effective for annual periods beginning on or after 1 January 2027, with early application permitted. For banks the main changes are:
- Scope 3 Category 15 can be limited to financed emissions; emissions linked to derivatives, facilitated emissions and insurance-associated emissions may be excluded, with a description of what was left out.
- The requirement to use GICS for industry breakdowns is relaxed; another classification system can be used if it gives more useful information, with an explanation.
- Where a jurisdiction requires a different GHG measurement method, that method can be used for the relevant part of the entity.
Each jurisdiction decides whether and when to adopt IFRS S2, so the effective date for your bank depends on local rules.
The RBI climate disclosure framework
On 28 February 2024 the Reserve Bank of India released the Draft Disclosure Framework on Climate-related Financial Risks, 2024, for public comment. Its main features:
- Who: scheduled commercial banks (other than local area banks, payments banks and regional rural banks), Tier IV primary urban co-operative banks, all-India financial institutions, and top- and upper-layer NBFCs; foreign banks for their Indian operations.
- What: the four pillars, with metrics including Scope 1, 2 and 3 emissions and financed emissions.
- When (as drafted): governance, strategy and risk management from FY 2025-26, and metrics and targets from FY 2027-28 for banks, AIFIs and large NBFCs; one year later for Tier IV UCBs.
- Where: standalone, as part of financial results or statements, reviewed by the board.
Current status
The framework has not been issued in final form as far as we can verify. In January 2026, Reuters reported, citing unnamed sources, that the RBI had put the plan to mandate climate risk disclosures on hold. Separately, on 28 November 2025 the RBI issued directions on climate finance and the management of climate change risks for regulated entities, including commercial banks; these deal mainly with green deposits and green finance frameworks and are not the climate risk disclosure framework.
The draft's phasing dates should not be treated as binding. Check the RBI's website for the latest status before planning to them.
Listed Indian banks are already reporting climate data through SEBI's BRSR, including their own Scope 1 and 2 emissions. See our BRSR Core guide. Building a financed emissions baseline now still makes sense: whatever form the RBI rules take, financed emissions are central to them and take several reporting cycles to get right.
Singapore: MAS and ISSB-based reporting
- MAS Guidelines on Environmental Risk Management (2020) set supervisory expectations for banks, insurers and asset managers on governance, risk management and disclosure of environmental risk.
- MAS Guidelines on Transition Planning, issued in March 2026 as an addendum to those guidelines, take effect in September 2027 after an 18-month transition. They expect institutions to engage customers and investees on transition risk, rather than withdraw finance indiscriminately, and to improve climate data over time.
- Listed companies, including listed banks, report Scope 1 and 2 emissions from FY 2025. Under changes announced by ACRA and SGX RegCo in August 2025, Straits Times Index constituents report ISSB-based climate disclosures from FY 2025 and Scope 3 from FY 2026, while timelines for smaller issuers were extended.
Global baseline: the Basel Committee
In June 2025 the Basel Committee on Banking Supervision published a voluntary framework for disclosing climate-related financial risks. Each jurisdiction decides whether to implement it, so check whether your supervisor has adopted it in full or in part.
Comparison of frameworks
| Framework | Status (October 2026) | Financed emissions |
|---|---|---|
| IFRS S2 | Issued 2023; amendments effective 1 January 2027; adoption set by each jurisdiction | Required for banks, asset managers and insurers |
| RBI disclosure framework | Draft (February 2024); not finalised | Included in draft metrics |
| MAS transition planning | Issued March 2026; effective September 2027 | Expects improving climate data and customer engagement |
| SGX climate reporting | In force for listed issuers, phased by size | Through Scope 3 for STI constituents from FY 2026 |
| BCBS framework | Voluntary (June 2025) | Jurisdictions decide |
What banks should do now
- Map obligations by entity and listing: IFRS S2-based rules, local banking regulator, exchange rules.
- Build a financed emissions baseline across PCAF asset classes, with data quality scores. See PCAF data quality scores.
- Choose metrics: absolute financed emissions, intensity and sector physical metrics. See WACI and financed emissions metrics.
- Embed climate risk in credit processes — sector heat maps, borrower questionnaires and scenario analysis.
- Set governance: board oversight, ownership and an evidence trail ready for assurance.
How EKOFIN helps
EKOFIN calculates financed emissions across PCAF asset classes, scores data quality, and tracks WACI, economic intensity and alignment with sector pathways. Counterparty data requests can be sent from the platform, and outputs are prepared for IFRS S2 and TCFD-style disclosure. A bank's own operational emissions can be measured in EKOTRACE. Ekobon also provides advisory on financed emissions and climate risk. See financed emissions and compliance risk.
Frequently asked questions
Is the RBI climate disclosure framework mandatory?
Not yet. The framework released in February 2024 was a draft, and as of October 2026 a final version has not been issued. Reports in January 2026 said the plan had been put on hold. Check the RBI's website for updates.
Do banks have to disclose financed emissions under IFRS S2?
Yes, where IFRS S2 applies. Commercial banks, asset managers and insurers must disclose financed emissions information. From 2027 the amendments allow derivatives, facilitated and insurance-associated emissions to be excluded from Category 15.
Is TCFD still relevant for banks?
Its four-pillar structure lives on in IFRS S2 and most national rules. The TCFD itself disbanded in 2023, so new reports should be framed against IFRS S2 or the local standard.
What do Singapore banks need to disclose?
Listed banks follow SGX climate reporting rules based on ISSB standards, phased by index membership and size. All banks are supervised under MAS environmental risk management guidelines, with transition planning expectations from September 2027.