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Contents 5
FINMA Circular 2026/1 “Nature-related Financial Risks” requires banks and insurers to systematically assess material climate-related and other nature-related financial risks. Materiality assessments and scenario analyses play a central role in this process. The requirements apply in stages: institutions in categories 1 and 2 must comply for climate-related financial risks from 1 January 2026, categories 3 to 5 from 1 January 2027, and the circular extends to all nature-related financial risks from 1 January 2028. A clearly defined governance structure, with responsibilities, competencies and relevant expertise documented within the institution, provides an important organisational foundation for carrying out these assessments effectively.
A clearly defined governance structure provides an important organisational foundation for the materiality assessment of nature-related risks under FINMA circular 2026/1: competencies and responsibilities for identification, assessment, management, monitoring and reporting need to be defined and documented. The board of directors, executive management, control functions and internal audit need sufficient expertise for this. This governance structure provides an important organisational foundation regardless of the applicable implementation deadline.
What does the circular fundamentally require?
The circular defines nature-related financial risks broadly and requires banks and insurers to identify, assess, manage and monitor these risks in a structured manner.
Under para. 9 of the circular, a nature-related financial risk is defined as the short-, medium- or long-term potential for direct or indirect effects on an institution arising from its exposure to climate-related and other nature-related risks. FINMA thus explicitly pursues a broad approach that goes beyond climate change and is aligned with international frameworks, as FINMA states in its media release dated 12.12.2024.
Excluded from the scope are institutions under CISA and FinIA, as well as institutions under the small banks and small insurers regimes. For all other institutions, the principle of proportionality applies: size, complexity, structure and business model determine how much detail the implementation requires, not the fundamental obligation itself.
Which deadlines apply to which institutions?
Institutions in categories 1 and 2 must meet the requirements of FINMA circular 2026/1 relating to climate-related financial risks from 1 January 2026, institutions in categories 3 to 5 from 1 January 2027, as the law firm Bratschi states in its analysis dated 16.4.2025. Only from 1 January 2028 does the circular apply to all nature-related financial risks.
This staggering matches FINMA’s announcement that the circular will initially apply exclusively to climate-related financial risks, before its scope widens to nature-related risks more broadly. Institutions in categories 4 and 5 also benefit from an additional relief: they are exempt from the quantitative approaches of the scenario analysis.
Other regulatory initiatives know similarly staggered transition periods, for instance the international Basel III deadlines running up to 2027. However, the staggering by category does not change the fact that a clearly defined governance structure provides an important organisational foundation for the assessment, for all institutions, regardless of the individual deadline.
What governance structure supports the materiality assessment?
Para. 14 of the circular requires institutions to define and document competencies and responsibilities for the identification, assessment, management, monitoring and reporting of nature-related risks.
This affects the governing body or Board of Directors and its committees, senior management, the independent control functions and internal audit. These bodies must perform their roles in line with the existing FINMA circulars 2017/1 on corporate governance for banks and 2017/2 for insurers, and must have sufficient expertise in nature-related risks.
FINMA’s explanatory notes on the circular further emphasise that the management of these risks must be adequately integrated into existing corporate governance frameworks. How responsibilities can be clearly delineated between internal audit and the other control functions is described in the updated three-lines model.
What does this mean for the scenario analysis itself?
Scenario analysis is an important tool for identifying and assessing material nature-related financial risks. It complements other qualitative and quantitative approaches to risk identification and materiality assessment. Scenario analyses must at minimum include qualitative considerations of adverse scenarios and their effects on the business model, including low-probability events.
For the design of risk identification, paras. 17 to 21 of the circular require that quantitative or qualitative indicators as well as materiality thresholds be considered for each individual risk. The scenario analyses themselves must incorporate various future developments, including low-probability events. Deviations from these requirements are possible in justified cases, and the periodicity of risk identification is likewise flexible.
The effectiveness of the instruments and methods used to mitigate risk must be assessed regularly. Methods, information and processes should be subject to review by internal or external experts, which makes clear organisational responsibility for such reviews particularly important.
What does this mean for preparation ahead of the deadline?
Institutions should establish the clearly defined governance structure required under para. 14 as part of their preparation, independently of their own deadline, as an important organisational foundation for any later scenario analysis.
A concrete first step: the board of directors and senior management determine which control function is responsible for identifying nature-related risks, which unit carries out the scenario analysis, and who reports the results to the governing body. This allocation should be clearly documented as part of the institution’s governance framework.
Institutions in categories 1 and 2 have until 1 January 2026 to do so for climate-related financial risks, institutions in categories 3 to 5 until 1 January 2027, with the scope widening to all nature-related financial risks from 1 January 2028, as set out in the deadlines of FINMA circular 2026/1. Addressing governance responsibilities only shortly before the applicable deadline can leave limited time for the subsequent substantive analysis and implementation.
Frequently asked questions
From when does FINMA circular 2026/1 apply to banks and insurers?
Institutions in categories 1 and 2 must meet the requirements relating to climate-related financial risks from 1 January 2026, institutions in categories 3 to 5 from 1 January 2027. The circular then applies to all nature-related financial risks from 1 January 2028. The staggering does not change the fact that the governance structure should be clearly defined and documented as part of the institution’s preparation for the applicable requirements.
Which institutions are exempt from FINMA circular 2026/1?
Excluded from the scope are institutions under CISA and FinIA, as well as institutions under the small banks and small insurers regimes. For all other banks and insurers, the principle of proportionality applies: size, complexity, structure and business model determine how much detail the implementation requires, not the fundamental obligation to carry out the materiality assessment itself.
Who within an institution is responsible for nature-related financial risks?
The board of directors or governing body, senior management, independent control functions and internal audit must perform their roles in line with the existing corporate governance circulars and must have sufficient expertise. Competencies and responsibilities for identification, assessment, management, monitoring and reporting must be documented in advance under para. 14.
Must all institutions carry out quantitative scenario analyses?
No. Institutions in categories 4 and 5 are exempt from the quantitative approaches of the scenario analysis. They must nevertheless document at least qualitative considerations of adverse scenarios and their effects on the business model, including low-probability events, as the circular generally requires for all institutions.
What counts as a nature-related financial risk under FINMA?
Under para. 9 of the circular, a nature-related financial risk is the short-, medium- or long-term potential for direct or indirect effects on an institution arising from its exposure to climate-related and other nature-related risks. FINMA thus pursues a broad approach that goes beyond climate change.
