Foreword
The Bank of England’s mission is to promote the good of the people of the United Kingdom by maintaining monetary and financial stability. Understanding the impact of climate risk on the financial system is part of that work. This disclosure reflects our commitment to transparency, accountability and collaboration. By sharing our progress and insights, we aim to contribute to the collective effort required to foster a resilient financial system and support sustained economic growth.
Sarah John
Chief Operating Officer of the Bank of England
Executive summary
This climate disclosure sets out the Bank of England’s (Bank’s) key climate-related developments in the year to 28 February 2025. It reports on:
- the climate-related risks (climate risks), to which the Bank is exposed;
- the emissions associated with the Bank’s own financial and physical operations; and
- the Bank’s work on climate change.
The disclosure follows the structure recommended by the Financial Stability Board’s (FSB’s) Task Force on Climate-related Financial Disclosures (TCFD).
Governance and strategy
Climate-related considerations are relevant to the Bank’s mission, functions and operations and are therefore embedded in its governance framework. The Bank’s climate strategy reflects the remit of the Bank’s statutory policy committees as specified by the Chancellor in their annual letters.footnote [1]
Risk management, metrics and targets
The Bank is exposed to climate risks across its physical and financial operations.
The Bank’s financial operations
Collectively, metrics suggest the Bank’s sovereign bond portfolios continue to be exposed to material climate risks, but the risks remain lower than for an international reference portfolio.
The value of the Bank’s sovereign bond holdings could decrease by over 9% in the most adverse climate scenario. This is comparable to previous years and assumes that markets price in the effects of the scenario on future interest rates and debt levels. This year’s scenario analysis uses the new Network for Greening the Financial System (NGFS) Phase V climate scenarios, as well as other methodological developments.
A new toolkit for assessing risks to counterparties in the Bank’s lending operations suggests that transition risks could materially impact on these counterparties’ Common Equity Tier 1 (CET1) ratio but would not threaten their solvency. The results are similar to the cumulative losses seen in the Bank’s Results of the 2021 Climate Biennial Exploratory Scenario (CBES).
The Bank’s physical operations
This year, the Bank’s carbon footprint from its physical operations is estimated at 61,215 tCO2e, 22% lower than 2023/24 and 58% lower than the baseline year (2015/16).
The most significant reduction relative to 2023/24 is a fall in estimated emissions from purchased goods and services and capital goods. The vast majority of this reduction is due to methodological improvements in estimation. This is illustrative of the Bank’s commitment to update its methodologies and engage with its suppliers to improve its risk management and reporting each year.
The Bank’s improved understanding of its 2024/25 emissions will enable it to refine estimates of emissions in earlier years, including the baseline year. A restatement of prior year emissions will be published in Summer 2026 in the update of the Climate Transition Plan (CTP). The Bank does not plan to restate prior year emissions before Summer 2026 because frequent restatements of the baseline year could create uncertainty and impact the Bank’s ability to embed its climate targets.
1: Governance and strategy
The physical effects of climate change and the transition to a net-zero economy (the transition) are relevant to the Bank’s mission because they create financial risks and economic consequences, which could affect:
- the safety and soundness of firms the Bank regulates;
- the stability of the financial system;
- the economic outlook in a way that could have a bearing on the appropriate monetary policy stance; and
- the financial resources and physical assets available to deliver the Bank’s policy and operational commitments.
Climate-related considerations are therefore embedded in its organisation-wide governance framework.footnote [2] The Bank’s climate strategy reflects the remit of the Bank’s statutory policy committees as specified by the Chancellor in their annual letters and is organised across three pillars (Figure 1.1).footnote [3]
Figure 1.1: The three pillars of the Bank’s climate strategy
Footnotes
- Source: Bank of England.
Box A outlines progress made against the Bank’s climate strategy since March 2024.
Box A: Progress against the Bank’s climate strategy
Pillar 1: Enhancing the resilience of individual firms and the wider financial system
In April 2025, the Prudential Regulation Authority (PRA) issued a consultation paper (CP10/25) on its proposal to update its existing supervisory expectations to help banks and insurers manage the effects of climate change on their businesses. It also published its third Climate Change Adaptation Report (CCAR)footnote [4] and wrote to CFOs of the major UK banks within scope of its written auditor reporting, providing thematic findings on their work to capture climate-related impacts to their balance sheets.footnote [5] With the FCA, the PRA continued to convene the Climate Financial Risk Forum (CFRF),footnote [6] issuing regular guidance.
Internationally, the Bank was active at the Basel Committee on Banking Supervision (BCBS),footnote [7] International Association of Insurance Supervisors, and the NGFS, where it contributed to the fifth vintage of the NGFS long-term climate scenariosfootnote [8] and the first vintage of the NGFS short-term climate scenarios.footnote [9]
The Bank continued to assess the systemic risks relating to climate change, as set out in the November 2024 Financial Stability Report. It confirmed in its publication, Key elements of the 2025 Bank Capital stress test, that the Financial Policy Committee (FPC) and Prudential Regulation Committee (PRC) continue to consider how to embed climate risks in stress-testing frameworks. And it continued to collaborate on the topic in international fora.footnote [10]
Pillar 2: Enhancing the resilience of the Bank of England to climate-related risks
This year, the Bank’s estimated carbon footprint from physical operations is 22% lower than 2023/24footnote [11] and it has continued to measure and mitigate climate risks to its financial operations. For example, in August 2024, the Bank began to reflect climate risks in the eligibility criteria and haircuts for residential mortgages posted as collateral in the Sterling Monetary Framework (SMF).footnote [12] The Bank’s current understanding is that it is the first central bank to calibrate haircuts in its monetary policy operations to reflect a quantitative assessment of climate risks.
The Bank continues to share its learnings on managing risks to enhance others’ capabilities where there is value in doing so.footnote [13] For example, in April 2024, the Bank published a Quarterly Bulletin article on its use of scenario analysis to measure climate risks associated with its own operations.
Pillar 3: Understanding how climate change and the transition to net zero impact the macroeconomy
The NGFS Workstream on Monetary Policy, chaired by James Talbot (Executive Director, International Directorate (ED, ID)) issued a report on adapting central bank operations to a hotter world, followed by three papers on climate change and monetary policy.footnote [14]
Building on this report and the Bank’s work in this area, Sarah Breeden (Deputy Governor Financial Stability) delivered a speech at the University of Edinburgh, advocating for the integration of more sophisticated climate policy analysis into monetary policy work.footnote [15] James Talbot (ED, ID) continued this theme in a speech at Oxford University and the Bank has published research on the topic.footnote [16] In fora such as the G7 and G20, the Bank supported the development of an international approach to assess and manage the risks to monetary stability from climate change.
2: Risk management, metrics and targets
The Bank is itself exposed to climate risks across its policy work, financial operations and physical operations. The risks arise through two primary categories: physical risks and transition risks.
Physical risks
Physical risks can arise from weather events, such as droughts, floods and storms and ‘chronic’ impacts, such as temperature rise and precipitation changes, which affect labour, capital and land.
If climate risks are not incorporated into banks’ and insurers’ pricing, climate-driven events can cause sudden price adjustments. For example, the value of mortgaged property can fall, resulting in lender losses if the mortgagor defaults. Insurance claims can exceed expectations, resulting in insurer losses and potentially reduced insurance availability and affordability. Such impacts can contribute to financial instability.
Transition risks
Transition risks are those connected to the adjustment towards a net-zero economy. They can arise from developments in climate policy, new technology, and impacts on supply chains. They can prompt a reassessment of the value of assets and create risks for banks and insurers.
Figure 2.1 sets out selected climate-related financial impacts and examples of how they could impact financial stability. Further information on the FPC’s approach to identifying and assessing climate-related financial stability risks can be found in the Section 3 of the November 2024 Financial Stability Report.
Figure 2.1: Selected climate-related financial impacts and examples of how they could impact financial stability
Footnotes
- Source: November 2024 Financial Stability Report, Figure 3.2.
Risk management
Climate risks to the Bank are identified, monitored and managed using the Bank’s risk management framework. Within that framework, climate change is identified as a ‘Key Risk Type’ and is overseen by a named ‘Risk Custodian.’
James Talbot (ED, ID) is Risk Custodian for climate change. Supported by the second line risk function, he is responsible for recommending to the Bank’s Audit and Risk Committee a set of risk metrics and tolerances to capture the operational and financial climate risks to which the Bank is exposed. He oversees the monitoring and reporting of those metrics and co-ordinates the timing and implementation of any mitigants.
The Bank also assesses climate risks across the near-term horizon through Risk and Control Self Assessments prepared by the Bank’s key functions and, for risks which are more uncertain or less proximate, through regular analysis of emerging risks.
Key climate-related risks in the Bank’s financial operations
Introduction
Financial operations covered in the Bank’s climate disclosures
The Bank engages in market operations to achieve monetary policy and financial stability. This includes holding fixed-income instruments and offering secured lending and repo to financial counterparties. To manage financial risks in secured lending and repo, the Bank manages a wide range of collateral. The Bank’s policy and balance sheet tools are set out in the Bank of England Market Operations Guide.
The largest proportion of the Bank’s financial assets is held in a separate legal vehicle, the Bank of England Asset Purchase Facility Fund,footnote [17] indemnified by His Majesty’s Treasury (HM Treasury). This was set up to implement the Monetary Policy Committee’s (MPC’s) asset purchase programme. Sterling UK government bonds (gilts) represent 100% of the Asset Purchase Facility (APF) and holdings in the APF have fallen, reflecting the MPC’s monetary policy decisions.footnote [18] In the past, the APF also included sterling corporate bonds acquired as part of the Bank’s Corporate Bond Purchase Scheme (CBPS). The Bank’s corporate bond holdings were fully unwound during the reporting period and none were held as of year-end.footnote [19]
The Bank’s Own Securities Holdings (OSH), composed of gilts and foreign currency reserves,footnote [20] are used for policy implementation and to fund the Bank’s policy functions.
In 2024, the Bank disclosed metrics relating to its lending operations and facilities,footnote [21] starting with the Bank’s Term Funding scheme with additional incentives for Small and Medium-sized Enterprises (TFSME).
The Bank is expanding its disclosure this year to include the Indexed Long-Term Repo (ILTR) and Short-Term Repo (STR) lending facilities. This is a result of the increasing materiality of repo exposures as part of the Bank’s transition to a repo-led and demand-driven operating framework.
Table 2.A: Financial exposures covered in this section (a) (b) (c)
Exposure | £ billions, end-February 2025 | Purpose | Composition |
---|---|---|---|
APF sovereign holdings | 477.4 | Mandated by the MPC. Held in a separate legal vehicle and indemnified by HM Treasury. | Gilts. |
Bank’s OSH | 20.0 | For policy implementation, and to fund the Bank’s policy functions. | Gilts, other sovereign, sub-sovereign, supranational and agency bonds. |
STR, ILTR and TFSME | TFSME: 96.7 | Combination of influencing market interest rates and ensuring firms have access to sufficient central bank reserves. | Counterparties are banks, building societies and investment firms. (d) |
STR: 58.2 | |||
ILTR: 9.7 |
Footnotes
- Source: Bank of England.
- (a) The asset values (APF and OSH) are stated at fair value, with the exception of the Bank’s OSH, which is stated at fair value plus accrued interest. Figures include mid to bid adjustment.
- (b) The Bank’s OSH include both the Bank’s Sterling Bond Portfolio and FX bonds.
- (c) TFSME, STR and ILTR outstanding drawings as at end-February 2025 are shown. To account for the short-term nature of the STR and ILTR schemes, metrics are derived on the basis of portfolio weights from the average of counterparties’ month-end drawings. Refer to footnote 41.
- (d) Investment firms refer to ‘Broker Dealers’, eligible for STR and ILTR. Refer to Results and usage data.
The Bank’s climate risk management framework evolves with best practice (Figure 3.1, The Bank’s climate-related financial disclosure 2024). It assesses and manages risks to its sovereign exposures, credit risk associated with financial institution counterparties, and risks to collateral. In the last year, the Bank has:
- enhanced methodologies to measure climate financial risks in sovereign bonds (Chart 2.2); and
- developed a toolkit to assess credit risks to financial institution counterparties (Chart 2.4).
The Bank’s climate-related financial risk metrics
The analysis in the Bank’s climate disclosure is based on asset holdings and market operations reported in the Bank’s Annual Report and Accounts as of 28 February 2025. Metrics draw on both publicly available and proprietary data from external providers.
To assess risk exposure in its financial operations, the Bank uses:
- Point in time metrics as proxies for exposure to transition and physical risks. These do not capture the likelihood or effectiveness of future decarbonisation strategies, and do not provide quantitative estimates of losses so they have limited decision usefulness for financial risk management.
- Forward-looking metrics, which incorporate planned actions by firms or governments to reduce exposure to climate-related financial risks. This makes them more decision useful but they do not provide quantitative estimates of losses.
- Scenario analysis metrics, which consider potential financial impacts of climate risks across a range of scenarios. This offers the most comprehensive measure of climate-related financial risks.
This year, the Bank has used climate scenario analysis to evaluate the potential impact on the credit risk of its SMF exposures.
Sovereign asset holdings
Point in time metrics including carbon footprint
The TCFD’s recommended metric for assessing the carbon footprint of an asset portfolio is Weighted Average Carbon Intensity (WACI).footnote [22] footnote [23]
The WACI of the sovereign assets held by the APF decreased from 216 tCO2e/£mn GDP in 2024, to 197 in 2025 (Chart 2.1). Given the monetary policy objectives of the APF, holdings are comprised entirely of gilts, so this reflects changes in the carbon intensity of the UK economy.
Footnotes
- Sources: Government of Canada Emissions and GDP data, United Nations Framework Convention on Climate Change greenhouse gas (GHG) emissions (2020, 2021 and 2022), World Bank GDP $ PPP (2017 constant prices, for 2020, 2021 and 2022, converted to GBP), World Bank public sector debt data for face value of debt outstanding for G7 countries and Bank calculations.
- (a) Emissions data for the 2023, 2024 and 2025 portfolios are from 2020, 2021 and 2022, respectively due to lags.
- (b) The G7 reference portfolio is calculated by weighting G7 countries according to the face value of debt outstanding during Q1 for each reporting period or the latest available data. This year’s disclosure uses outstanding debt data from the World Bank, while previous years used Bloomberg Finance L.P. data to ensure consistency across years given variations in the methodology of the previous series. The change increases the G7 reference WACI by +3 tCO2e/£mn GDP for 2023 and reduces it by -2 for 2024.
- (c) The reported 2023 and 2024 WACI metrics in last year’s climate disclosure were 223 tCO2e/£mn GDP and 218 (APF Sovereign) and 271 tCO2e/£mn GDP and 268 (Bank’s OSH), respectively. These figures have been restated to reflect methodological changes as well as revisions to external source data.
- (d) Agency bonds are attributed the carbon intensity of their sovereign.
The WACI of the Bank’s OSH increased slightly, from 264 tCO2e/£mn GDP in 2024 to 272 in 2025. The increase was driven by increases in the portfolio weights of issuers with higher carbon intensities, reflecting the Bank’s policy objectives, returns and risk.
The WACI of both the APF and OSH portfolios remain materially lower than a G7 reference portfolio, where carbon intensity fell from 399 tCO2e/£mn GDP to 383 year-on-year, driven by all G7 sovereigns reducing their carbon intensity.
Sovereign emissions data are presented with a three-year lag. Therefore, the reduction in UK carbon intensity was driven by strength in UK GDP growth over 2022, as the economy continued to recover from the pandemic. In addition, the UK emissions also fell over the year, further contributing to the reduction in UK carbon intensity and the APF WACI.
Emissions data in Chart 2.1 are on a ‘production basis’: ie emissions from goods and services produced within a country. In 2024, the Bank disclosed ‘consumption-based’ WACI for the first time. Consumption emissions measure emissions associated with goods and services consumed in a country, regardless of where they were produced. Consumption emissions may be less directly linked to transition risks, as economies may find it easier to adjust consumption than replace production. Nevertheless, they provide a useful complement to production-based emissions and proxy risks associated with the transition of the economy’s demand side to net zero.footnote [24]
Consumption-based WACIs continue to be significantly higher than production-based WACIs because the advanced economies the Bank is exposed to are net importers of carbon-intensive goods. Consumption-based WACI for the APF decreased from 380 tCO2e/£mn total consumption expenditure in 2024 to 350 in 2025, and from 416 tCO2e/£mn to 409 for the OSH.footnote [25] footnote [26]
Forward-looking metrics
Implied Temperature Rise (ITR) metrics estimate the global average temperature rise if the world were to overshoot its carbon budgets by the same proportion as the sovereigns in our portfolios are projected to. It provides an indication of the level of transition risk: countries with an ITR close to 1.5oC are planning to reduce emissions significantly, which may reduce the macroeconomic cost of transition.
We measure ITRs for two different emissions pathways. One considers expected future emissions given countries’ current policies (Current Policies). The other is based on emissions reductions that countries have committed to under the Paris Agreement: Nationally Determined Contributions (NDCs).footnote [27]
In a NDCs scenario, the ITR of the APF and the Bank’s OSH is 1.65oC and 1.66oC, respectively.footnote [28] In a Current Policies scenario, the ITR of the APF and the Bank’s OSH is 1.71oC and 1.72oC, respectively. These are marginally lower than the ITR for a G7 reference portfolio and similar to those published in the 2024 disclosure.footnote [29]
Scenario analysis
The Bank uses scenario analysis to understand the climate risks in its sovereign portfolios and estimate financial losses. The analysis considers shocks to the risk-free component of interest rates and risk premia based on NGFS climate scenarios out to 2050.
This year the Bank’s analysis has been updated to use the NGFS Phase V climate scenarios. While the economic impacts of physical risks projected in Phase V are larger than Phase IV, they now capture both chronic and acute physical risks. The Bank previously combined its own estimates of acute physical risks with chronic physical risk projections. The result is the transition from Phase IV to Phase V scenarios largely net out and overall losses in the highest transition and physical risk scenarios are comparable to previous years.
The analysis assumes risks are not currently priced and that markets reprice assets to reflect expected shocks to sovereign yields.footnote [30] This is a tail-risk assumption which estimates the impact of a worst-case repricing scenario.
Projected losses should not be mistaken for macroeconomic impacts. From a macroeconomic perspective, impacts of different climate scenarios on economic variables such as real GDP are likely to be much more relevant than changes in interest rates.
In the scenario with the largest consequences for bond prices, the APF value falls by ‑9.4%. The value of the OSH falls by -5.3% (Chart 2.2). Net Zero 2050 has the largest combined shocks across the yield curve, significantly reducing the value of sovereign bond portfolios. Shocks at the short end of the curve are from movements in the risk-free component of interest rates as countries increase short-term interest rates to counteract inflation from high carbon pricing.footnote [31] Shocks at the long end of the curve are exacerbated by increases in risk premia, driven by the crystallisation of physical climate risks.
In the Current Policies scenariofootnote [32] the value of the APF falls by -3.6%. The value of the Bank’s OSH falls by -0.9%. There are no shocks to policy rates in the Current Policies scenario. While monetary policy may respond to physical risks, these are not currently modelled by the NGFS due to uncertainty over the scale and direction of impacts.footnote [33] The entire Current Policies shock is therefore driven by significant increases in physical risks that drive up sovereign credit risk premia. These physical risks take particularly long to crystallise and mainly affect long maturity securities in the APF. The NDCs scenario has losses in between Net Zero 2050 and Current Policies (-7.6% for the APF and -3.7% for OSH) because it combines elements from both the Current Policies and Net Zero 2050 scenarios.
Chart 2.2: Impact of climate-scenarios on the Bank’s sovereign bond portfolios (a)
Footnotes
- Sources: The Annex of Holden et al (2024), Measuring climate-related financial risks using scenario analysis, provides a full breakdown of data sources used in the Bank’s model and Bank calculations.
- (a) Analysis undertaken on 80% of the APF portfolio and 77% of the OSH at end-February 2024. Analysis excludes securities with the shortest remaining time to maturity. This is because these securities are less likely to be subject to a future climate-related repricing event and are relatively insensitive to interest rate shocks.
Across all scenarios, the APF is exposed to greater losses than the Bank’s OSH. This is because the duration of bonds in the APF is longer than the Bank’s OSH and hence more sensitive to interest rate shocks. In addition, longer maturity bonds are more exposed to physical risks which crystalise later in the scenario.
Assessing the design of the CBPS greening framework
Between 2016 and 2024, the APF included up to £20 billion of corporate bonds that the Bank acquired via its CBPS. In November 2021, the Bank published a framework for greening the CBPS. The CBPS has now unwound and the Bank no longer has outright holdings of corporate bonds as of the reporting date.footnote [34] The Bank has reviewed the actions it took and sets out its key learnings below.
Background
The Bank’s approach to greening the CBPS involved four tools:
- Targets: A 25% reduction in WACI by 2025 and net-zero emissions by 2050.
- Eligibility: Climate-related criteria for eligibility.
- Tilting: Within each sector, the Bank tilted purchases toward stronger climate performers and away from weaker ones.
- Escalation: Escalation of requirements over time.
In November 2021, the Bank began to implement greening the CBPS and applied these criteria to upcoming reinvestment rounds. The green tilting was only operational for the reinvestment programme that took place between November 2021 and January 2022. After January 2022, the Bank started unwinding the CBPS due to monetary policy considerations. Over the months of green tilting, approximately £600 million of reinvestments occurred – 3% of the CBPS. Reinvestments took place for bonds issued by the Water, Property and Finance, Electricity and Energy sectors, to ‘top-up’ sector weights back to target proportions.
Impact of green tilting on probability of purchasing different types of bonds
The greening of the CBPS tilted purchases within sectors towards bonds of firms that were stronger climate performers. Stronger climate performers were those with lower carbon intensities, larger historical reductions in absolute emissions, climate-related financial disclosures, and emissions reduction targets verified by a third party.
Based on their performance across these metrics, firms were given a climate score and allocated into one of four buckets. Bucket A represented the strongest climate performers within a sector, Bucket D the weakest. All else equal, the Bank was prepared to pay a higher price for bonds issued by greener firms. However, the probability of bonds being purchased was also a function of market supply and other considerations.
The Bank’s green tilting approach successfully increased the probability of a bond being purchased if it had a higher climate score (Chart 2.3). Bonds in the strongest climate bucket were 54 percentage points more likely to be purchased than bonds in the lowest bucket.
Chart 2.3: Change in probability of purchase of a bond depending on climate bucket (a)
Impact of green tilting on bond spreads
There is no evidence green tilting influenced market prices. The higher probability of buying greener bonds did not result in lower yield spreads compared to bonds from issuers with weaker climate performance within the same sector. Tilting was operational for three months and the limited amount of reinvestment likely muted impacts.
The Bank found no effect on bond spreads for strong climate performers following the announcement of the CBPS greening. In well-functioning markets, credible bond purchase announcements from central banks can influence yields even before purchases are made. Previous work found that upon announcement of the CBPS, spreads of eligible bonds decreased. However, similar effects were not observed for the announcement of the ‘greening’ of the CBPS. This may be because announcement of greening of the CBPS only communicated a high-level approach and did not explicitly list issuers considered stronger climate performers.footnote [35]
SMF and TFSME
Consistent with the increasing materiality of repo exposures due to the Bank’s transition to a repo-led and demand-driven operating framework, the Bank is expanding the scope of its disclosure to consider climate-related financial risks via secured lending and repo operations. This disclosure covers:footnote [36]
- Short-Term Repo – STR provides central bank reserves for one-week against the highest quality collateral. STR was introduced to ensure that short-term market interest rates remain close to Bank Rate.
- Indexed-Long-Term Repo – ILTR provides central bank reserves for routine sterling liquidity management for a six-month term against the full range of collateral.
This is in addition to the TFSME, which the Bank started reporting in its disclosure last year. This scope expansion ensures the Bank continues to disclose its exposure to material climate-related financial risks across its range of financial operations.
This section broadly follows the recommendations of the TCFD for banks to assess climate-related financial risks in loan portfolios by assessing the climate risk associated with a bank’s counterparties. In addition, the Bank manages climate-related financial risks to which it is exposed through the collateral it receives against these operations.
The STR, ILTR and TFSME provide financing to financial institutions (banks). Banks subsequently lend to households and the real economy. Emissions associated with this lending to the real economy are banks’ Scope 3 financed emissions,footnote [37] which make up the majority of banks’ total emissions. The Bank therefore focuses on estimating these emissions as a proxy for its exposure to climate-related financial risks.
As discussed in Box C of the Bank’s climate-related financial disclosure 2024, the current quality, coverage and comparability of banks’ Scope 3 emissions disclosures is limited. While estimation methodologies have been developed, these are not always comparable across banks with different business models.
To estimate banks’ Scope 3 emissions intensity on a comparable basis, the Bank developed its own estimation model for banks’ loan books.footnote [38] footnote [39] This uses:
- granular information on banks’ loan books from publicly available sources, with breakdowns of lending by type, geography and sector;
- estimation of emissions intensity of a representative sample of banks’ counterparties, for example firms within the same sector and geography for corporate lending; and
- estimates of banks’ interest revenues associated with lending activities.
The model estimates emissions for all corporate lending, as well as residential and corporate real estate loans.footnote [40] While the model provides a comprehensive overview, it may not account for granular policies, which banks might have in place. For example, to limit exposure to the highest carbon intensity counterparties.
The Scope 1 and 2 WACI for the combined STR, ILTR and TFSME portfoliofootnote [41] was 2.0 tCO2/£mn revenue.footnote [42] footnote [43] footnote [44] Scope 1 and 2 emissions represent an immaterial portion of firms emissions and are of limited utility when assessing exposure to climate-related financial risks.
The Scope 3 WACI for the combined STR, ILTR and TFSME portfolio was 768.8 tCO2/£mn interest revenues (Chart 2.4).footnote [45] This is an order of magnitude higher than Scope 1 and 2 WACI, which only captures banks operational emissions (eg offices).
The Scope 3 WACI is significantly lower than a sample of large, international banks. For example, the Scope 3 WACI for a global systemically important bank (G-SIB) G7 reference portfoliofootnote [46] would be 2,737 tCO2/£mn interest revenues.footnote [47] Differences in Scope 3 WACI reflect differences between the business model of those banks that the Bank lends to via the STR, ILTR and TFSME compared to the sample international bank’s portfolio. It does not reflect the nature of the collateral that this lending is secured against:
- Revenues (33% of difference): firms in the reference portfolio generate less interest revenue for a given quantity of emissions. This is particularly driven by the low interest rate environment in Japan and material weighting of Japanese banks in the reference portfolio.
- Geography (13% of difference): where firms in the G-SIB G7 reference portfolio lend to counterparties with the same characteristics, the location of those counterparties means those exposures are generally higher carbon intensity.
- Counterparty type (54% of difference): firms in the G-SIB G7 reference portfolio lend to counterparties with higher emissions. For example, they have higher weights of corporate lending than residential real estate, which is more carbon intensive.
An extension of this approach is used to quantify financial risks banks face (Chart 2.4). For example, the impact of a transition shock on residential mortgage probability of default (PD), and banks’ expected credit losses (ECLs), is estimated in line with the methodology described in Measuring climate-related financial risks using scenario analysis. For corporate loans, the Bank applies a structural credit risk model to estimate the impact of climate-related falls in the long-term value of a corporate’s assets into ECLs. While this approach may overstate the speed at which changes in the value of corporates’ assets would translate into elevated ECLs, it is valuable for exploring tail risks. Aggregate ECLs are translated into an estimated impact on CET1 ratios. CET1 ratios are widely used as a measure of firms’ resilience to shocks.
In a High Transition Risk scenario,footnote [48] the weighted average CET1 ratio of the STR, ILTR and TFSME portfolio reduces by around -1.7 percentage points of risk-weighted assets (RWAs) (Chart 2.4). These reductions are smaller than the G-SIB G7 reference portfolio, which reduces by around -2.7 percentage points. All these numbers are desk-based, top-down estimates derived using a series of conservative assumptions, given our objective of quantifying tail financial risks to the Bank. They are of a similar order of magnitude to, but slightly larger than, the cumulative losses seen in the CBES. This reflects the additional conservatism of our approach, which pulls forward losses that may only accrue later. The numbers are also similar to results from scenario analysis exercises undertaken by other central banks and supervisors (eg European Central Bank and Bundesbank).
Footnotes
- Sources: Bank estimation model, CBES variable pathways, Energy Performance of Buildings Register, firm annual reports, LSEG, MSCI, NGFS Phase V Scenario Explorer and Pillar III credit risk disclosures and environmental disclosures.
- (a) Changes in CET1 ratios are derived by estimating climate induced ECLs. No allowance for changes in RWAs is made. ECLs are estimated from modelling changes in PD. In the corporate book these are estimated by creating proxy portfolios of corporates with the same sector and geography characteristics as firms’ loan books. The Bank takes estimates from its external data provider, MSCI, of future cash-flow changes for these corporates in climate stress scenarios. In the High Transition Risk scenario, reductions in corporates’ cash flows are driven by their exposure to projected shadow carbon prices. Future cash flows are discounted to estimate a change in enterprise value today. In effect, this assumes investors have foresight over future transition risks and fully price these today. Finally, firms’ estimated enterprise values feed a structural credit risk model to estimate a change in PD. The stressed PD is used to estimate stressed ECLs and ultimately a stressed CET1 ratio. Changes in PD in the residential mortgage book capture two effects. First, for owner-occupied mortgages, Energy Performance Certificates (EPC) ratings are used to assess the impact of an aggregate energy price shock on households’ debt-servicing ratios. The methodology was described in Measuring climate-related financial risks using scenario analysis. For buy-to-let mortgages, mortgages secured on properties with EPC F and EPC G ratings are assumed to default. This approach aligns with the Domestic private rented property: minimum energy efficiency standard - landlord guidance, which requires rental properties in England and Wales to have a current EPC rating of at least ‘E’ or a valid exemption. Second, the macroeconomic impacts of a disorderly macroeconomic transition (eg unemployment and house price impacts) on PDs is estimated. No upside benefits are estimated, consistent with the Bank’s objective of exploring tail risks within these climate scenarios.
- (b) Changes in CET1 ratios are expressed relative to a hypothetical baseline scenario without climate risk.
Overall, STR, ILTR and TFSME firms’ Scope 3 emissions intensity is much lower than a sample of large international banks due to lower exposures to the most intensive form of lending – corporate lending – and higher interest revenues. This feeds into financial risk metrics, where STR, ILTR and TFSME firms are less exposed to higher ECLs and reductions in their capital ratios compared to international peers. While these reductions in CET1 ratios are material, they are smaller than the reductions in CET1 ratios which firms see as part of the Bank’s regular stress tests (eg November 2024 Financial Stability Report). Moreover, the UK banking system would have enough capital to absorb such losses without breaching minimum capital requirements based on current levels of capital. Overall, this suggests the Bank is exposed to relatively limited climate-related credit and financial risks through the STR, ILTR and TFSME.
Key climate-related risks in the Bank’s physical operations
The Bank’s physical operations are those related to the management and operation of its property, plant and equipment, the manufacture of banknotes, and all other non-financial activities. The Bank’s physical operations are exposed to both physical and transition risks.footnote [49]
The Bank’s carbon footprint for physical operations
One way in which the Bank monitors its exposure to transition risks is by tracking its carbon footprint from physical operations.
This year the Bank’s carbon footprint is estimated to be 61,215 tCO2e. The majority of emissions relate to goods and services purchased by the Bank (73%), capital goods purchased (10%), business travel (5%) and employee commuting (5%). It is estimated that emissions would rise by 5,482 tCO2e if renewable electricity were not used in 2024/25, which would represent a 9% increase in the Bank’s physical operations carbon footprint.footnote [50] footnote [51]
Table 2.B summarises the Bank’s reported carbon footprint from physical operations for the current year, the previous year and the 2015/16 baseline. As explained in the Bank’s climate-related financial disclosure 2024, data in previous years are not restated to reflect the methodological improvements incorporated in 2023/24. The same approach has been taken in 2024/25.
Table 2.B: The Bank’s carbon footprint from physical operations (a)
Type of emissions (b) | 2024/25 (tCO2e) | 2023/24 (tCO2e) | 2015/16 |
---|---|---|---|
Scope 1 | 2,275 | 2,357 | 3,154 |
Scope 2 | – | – | 5,563 |
Scope 3 category 1: purchased goods and services | 44,745 | 56,937 | 109,068 |
Scope 3 category 2: capital goods | 6,176 | 10,703 | 16,358 |
Scope 3 category 3: fuel and energy related activities | 1,685 | 1,711 | 3,991 |
Scope 3 category 5: waste | 3 | 10 | 32 |
Scope 3 category 6: business travel | 3,067 | 3,967 | 4,367 |
Scope 3 category 7: employee commuting | 3,264 | 3,234 | 1,844 |
Total | 61,215 | 78,919 | 144,377 |
Footnotes
- Source: Bank of England.
- (a) This table includes certain information 2025 © MSCI ESG Research LLC, reproduced by permission.
- (b) Under the GHG Protocol, Scope 1 emissions are direct emissions (eg from running boilers), Scope 2 emissions are indirect emissions from electricity use (eg from powering its office buildings), and Scope 3 emissions are upstream and downstream value chain emissions (eg emissions from buying products from suppliers and emissions from products when customers use them).
Comparison with prior year
The Bank’s estimated carbon footprint this year is 22% (17,704 tCO2e) lower than 2023/24 (78,919 tCO2e). This was mainly due to a fall in estimated emissions from purchased goods and services (12,192 tCO2e) and capital goods (4,527 tCO2e). The vast majority of these reductions were driven by methodological improvements rather than changes in the type and quantity of goods and services purchased (Chart 2.5). This is illustrative of the Bank’s commitment to update its methodologies and engage with its suppliers to improve its risk management and reporting each year.
Chart 2.5: Factors contributing to the reduction in Scope 3 Category 1 and 2 emissions between 2023/24 and 2024/25 (a)
Footnotes
- Source: Bank calculations.
- (a) The Bank uses a spend-based methodology to calculate its Scope 3 Category 1 and 2 emissions. The categorisation of the year-on-year emissions reduction between methodological change and abatement is achieved by applying the 2023/24 methodology to the 2024/25 spend data.
Comparison with baseline year
The Bank’s estimated carbon footprint this year is 58% (83,162 tCO2e) lower than the baseline year (144,377 tCO2e). The methodological changes to improve the quality of the current year emissions estimates have driven a substantial proportion of the reduction in emissions from purchased goods and services (64,323 tCO2e) and capital goods (10,182 tCO2e). A further reduction of 5,563 tCO2e is driven by abatement of emissions via the Bank’s move to renewable electricity.
The Bank’s carbon targets for physical operations
In 2022/23 the Bank published its first CTP, setting out its approach to reduce emissions from physical operations to net zero by 2040. The Bank expects to meet this target. The Bank continues to monitor its previous 2030 Target to reduce selectedfootnote [52] GHG emissions by 63% from 2016 to 2030footnote [53] and has incorporated it within the CTP transition pathway.footnote [54] The Bank expects to meet the 2030 Target, due in large part to its move to renewable energy. Both targets align with the reduction in emissions needed to limit the rise in global average temperatures to 1.5°C above pre-industrial levels.
Annex
The PRC
The PRA’s statutory objectives include both primary and secondary objectives. The primary objectives are the general objective, to promote the safety and soundness of the firms the PRA regulates, and the insurance objective, to contribute to the securing of an appropriate degree of protection for insurance policyholders. The secondary objectives are to facilitate: (i) effective competition; and (ii) the international competitiveness of the UK economy and its growth in the medium to long term. Climate is relevant to both the primary and secondary objectives.
In addition, the PRA should have regard to regulatory principles that are set out in statute when discharging its general functions, including ‘the need to contribute towards achieving compliance by the Secretary of State with section 1 of the Climate Change Act 2008 (UK net-zero emissions target) and section 5 of the Environment Act 2021 (environmental targets) where each regulator considers the exercise of its functions to be relevant to the making of such a contribution’.
The PRA should also have regard to recommendations from HM Treasury about aspects of the Government’s economic policy when considering how to advance its primary and secondary objectives and the application of the regulatory principles. Recommendations are issued at least once every Parliament and, at the time of publication, the most recent recommendations were issued in November 2024.
The FPC
The FPC contributes to achieving the Bank’s financial stability objective (the FPC’s primary objective) and, subject to that, supporting the economic policy of the UK Government, including its objectives for growth and employment (the FPC’s secondary objective). Climate is relevant to both the primary and secondary objectives.
The FPC’s primary and secondary objectives are refined and informed by HM Treasury’s remit and recommendations letter, which is issued at least once every calendar year. At the time of publication, the most recent FPC remit and recommendations letter was issued in November 2024.
The MPC
The MPC’s statutory objectives include both primary and secondary objectives. The primary objective is to maintain price stability. The secondary objective is subject to the primary objective and is to support the economic policy of the UK Government, including its objectives for growth and employment (the MPC’s secondary objective). Climate is relevant to both the primary and secondary objectives.
The MPC’s secondary objective is refined and informed by HM Treasury’s remit letter, which is issued at least once every calendar year. At the time of publication, the most recent MPC remit letter was issued in November 2024.
The Financial Market Infrastructure Committee (FMIC)
The Bank’s primary objective as Financial Markets Infrastructure (FMI) regulator is to protect and enhance the stability of the financial system of the UK (the financial stability objective).
In exercising its FMI functions, the Bank also has a secondary objective to, as far as reasonably possible, facilitate innovation in the provision of central counterparty and central securities depository services with a view to improving the quality, efficiency, and economy of the services. Climate is relevant to both the primary and secondary objectives.
In addition, in exercising its FMI functions, the Bank must have regard to regulatory principles, including ‘the desirability of sustainable growth in the economy of the United Kingdom in the medium or long term, including in a way consistent with contributing towards achieving compliance by the Secretary of State with section 1 of the Climate Change Act 2008 (UK net-zero emissions target) and section 5 of the Environment Act 2021 (environmental targets) where the Bank considers the exercise of its FMI functions to be relevant to the making of such a contribution’.
The annex provides further information on the relevance of climate risk to the Bank’s policy committees.
The Bank’s approach to governance of its climate-related activities remains the same as in 2023/24, with one exception: In April 2025, Sarah John succeeded Ben Stimson as Deputy Governor, Chief Operating Officer, with responsibility for climate risks to the Bank’s physical operations. An overview of the Bank’s approach to governance is set out in Section 1 of the Bank’s climate-related financial disclosure 2024.
The annex provides further information on the relevance of climate risk to the Bank’s policy committees.
The CCAR was published in response to an invitation by the Department of Environment, Food and Rural Affairs. It sets out steps taken by banks and insurers, since the PRA’s last CCAR, to respond to climate-change impacts and outlines how the PRA’s regulatory work has evolved over the period.
The Bank first identified the need for banks to focus on high-quality and consistent accounting for climate change in the letter to CFOs issued by the Bank in 2022 and a second letter was issued in 2023.
The CFRF is an industry group established to share best practice on climate issues and accelerate firms’ capabilities to address climate change.
The BCBS has published a discussion paper on the role of climate scenario analysis in strengthening the management and supervision of climate risks.
These scenarios are also known as the NGFS Phase V climate scenarios.
The NGFS short-term scenarios aim to assist policymakers and financial users to assess the near-term effects of climate policies and climate change on financial stability and economic resilience.
For example, through Sarah Breeden’s (Deputy Governor Financial Stability) role as chair of the FSB’s Climate Vulnerabilities and Data group, which published an analytical framework and toolkit for assessment of climate-related vulnerabilities in January 2025.
The vast majority of these reductions were driven by methodological improvements rather than changes in the type and quantity of goods and services purchased.
The Bank manages around £500 billion of collateral, 85% of which consists of residential mortgages.
This is done through a variety of channels, including: the NGFS Workstream Net Zero; the Centre for Central Banking Studies, a Bank team, which provides training to other central banks and regulators; and the Climate Training Alliance Portal, an online platform run jointly by the Bank and the NGFS, which centralises climate and environmental risks training resources to build knowledge and expertise among central banks and supervisors.
These papers are summarised in the November 2024 report: Climate change, the macroeconomy and monetary policy. James Talbot’s (ED, ID) Dow Lecture on climate change, the macroeconomy and monetary policy also touched on some of these topics.
Catherine L. Mann (Monetary Policy Committee member) has also spoken on this topic: Holding the anchor in turbulent waters – speech by Catherine L. Mann.
Weathering the storm: sectoral economic and inflationary effects of floods and the role of adaptation (February 2025); The effect of subsidized flood insurance on real estate markets (November 2024); and Climate actions, market beliefs, and monetary policy (February 2024).
APF: Bank of England concludes corporate bond sales programme – Market Notice 6 June 2023.
WACI is in tCO2e/£m, with GDP in constant 2017 prices. The constant prices approach ensures WACI does not deflate over time due to inflation in GDP.
Sovereign financed emissions (SFE) is an alternative carbon footprint measure. It is not adjusted for the portfolio size and increases with portfolio size. This means it does not provide a sense of transition risks relative to an institution’s ability to absorb risks. The SFE of the APF fell to 94.3 MtCO2 in 2025 from 119.3 in 2024, which reflects the reduction in the carbon intensity of the UK as well as the reduction in the size of the APF. The SFE for OSH increased to 4.9 MtCO2 in 2025, versus 4.7 in 2024.
Partnership for Carbon Accounting Financials (PCAF) recommends normalising consumption emissions on a per capita basis. The Bank reports a variant of this, normalised by consumption expenditure.
This year, the Bank has used consumption emissions estimated by MSCI, which captures all GHG emissions with a three-year lag. In 2023/24, the Bank used consumption emissions data from the Organisation for Economic Co-operation and Development, which only captured CO2 emissions with a six-year lag.
Certain information contained herein (Information) is sourced from/copyright of MSCI Inc., MSCI ESG Research LLC, or their affiliates (MSCI), or information providers (together, the MSCI Parties) and may have been used to calculate scores, signals, or other indicators. The Information is for internal use only and may not be reproduced or disseminated in whole or part without prior written permission. The Information may not be used for, nor does it constitute, an offer to buy or sell, or a promotion or recommendation of, any security, financial instrument or product, trading strategy, or index, nor should it be taken as an indication or guarantee of any future performance. Some funds may be based on or linked to MSCI indexes, and MSCI may be compensated based on the fund’s assets under management or other measures. MSCI has established an information barrier between index research and certain Information. None of the Information in and of itself can be used to determine which securities to buy or sell or when to buy or sell them. The Information is provided ‘as is’ and the user assumes the entire risk of any use it may make or permit to be made of the Information. No MSCI Party warrants or guarantees the originality, accuracy and/or completeness of the Information and each expressly disclaims all express or implied warranties. No MSCI Party shall have any liability for any errors or omissions in connection with any Information herein, or any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) even if notified of the possibility of such damages.
Sources: Climate Action Tracker for reference emissions pathways and sovereign issuers NDCs and Current Policies emissions pathways to 2030, Intergovernmental Panel on Climate Change for global carbon budgets and transient climate response from cumulative emissions estimates, World Bank public sector debt data for face value of debt outstanding for G7 countries and Bank calculations.
This analysis calculates emissions overshoots relative to a reference pathway to 2030. It assumes the sovereign’s overshoot in 2030 equals the total overshoot it will have against its 2oC aligned budget. While this works for ambitious emissions reductions pathways (such as NDCs), it works less well when sovereign’s emissions remain elevated and do not achieve net zero. To explore this effect, we supplement Climate Action Tracker data with NGFS data for projected country emissions pathways out to 2050. Taking this approach results in a World ITR of over 2oC.
A detailed summary of the methodology can be found in our April 2024 Quarterly Bulletin article.
Interest rates respond to inflation according to a simple Taylor Rule. See NGFS Climate Scenarios Technical Documentation V5.0.
The Current Policies scenario assumes that only currently implemented policies are preserved, leading to high physical risks.
See The implications of severe weather events for the economy and monetary policy for a discussion of the way in which acute physical risks could affect monetary policy. Depending on whether disasters would constitute a demand or supply shock, inflation might either increase or decrease.
APF: Bank of England concludes corporate bond sales programme – Market Notice 6 June 2023.
Market participants anticipating scheme wind down may also have played a part.
A range of smaller facilities and facilities where limited results data is published remain out of scope. Refer to Results and usage data.
Scope 3 Category 15 emissions. Refer to GHG Protocol and PCAF Standard.
Emissions and revenues associated with other banking activities (eg asset management and investment banking) are excluded.
Financed emissions and interest revenues are estimated for firms representing 97% of outstanding STR, TFSME and ILTR exposures. Data coverage is 100% for the G-SIB G7 reference portfolio.
In line with PCAF guidance we make no estimate of emissions associated with non-residential consumer finance. Revenues associated with non-residential consumer finance are estimated and removed from banks’ interest revenues to ensure alignment between denominator and numerator.
TFSME lending is long-term, while STR has a one-week term and ILTR a six-month term. TFSME weights are calculated from outstanding drawings as at the reporting date. Taking the same approach for STR and ILTR would not capture volatility over the reporting year. To account for this, STR and ILTR weights are derived by taking an average of all month-end outstanding amounts. This approach is consistent with PCAF financed emission standard.
Source: MSCI.
Due to data availability and lags in firm reporting, these data relate to firms’ emissions and revenues in the financial year ending 2023.
Scope 1 and 2 financed emissions were 0.1 MtCO2e. Scope 1 and 2 financed emissions are based on 90% of total drawings due to data limitations.
Scope 3 financed emissions were 6 MtCO2e. Scope 3 financed emissions are based on 90% of total drawings due to data limitations.
The G-SIB G7 reference portfolio is defined as firms in the FSB’s 2024 list of G-SIBs, which are domiciled in G7 countries. It is weighted by outstanding loans as at reporting periods ending in 2024.
Sources: Bank estimation model, firm annual reports, LSEG, MSCI, National Statistical and Energy Agencies and Pillar III credit risk disclosures and environmental disclosures.
This scenario incorporates variables from both the NGFS Phase V Net Zero 2050 scenario and the Bank’s CBES Late Action scenario. The Phase V Net Zero 2050 scenario is used to estimate changes in corporate default probability, as well as macroeconomic impacts such as changes in house prices and unemployment. The CBES Late Action scenario is used to estimate changes in residential mortgage default probability based on changes in households’ debt-servicing costs due to an energy price shock. Further information on these methodologies can be found in Measuring climate-related financial risks using scenario analysis.
All figures in this section are quoted to the nearest integer, unless stated otherwise.
The Bank uses an electricity supply contract matched by Renewable Energy Guarantee of Origin (REGO). Further information on REGOs and their use by the Bank is set out in the Bank’s climate-related financial disclosure 2023.
This calculation uses the UK national average carbon factor for electricity to estimate the carbon emissions associated with the Bank’s electricity consumption. Further information on the Bank’s energy consumption is available in ‘Related documents’.
The sources of GHG emissions included in the 2030 Target are limited to Scope 1 emissions (use of natural gas, fuel and refrigerants), Scope 2 emissions (electricity) and travel emissions (which fall within Scope 3). For further information see Annex 3 of the Bank’s climate-related financial disclosure 2022.
The target is informed by the Science Based Targets initiative (SBTi) methodology and has been verified by the Carbon Trust as consistent with aligning emissions from the Bank’s physical operations to the goals of the Paris Agreement. Further information on the scope and calculation of this target is set out in Annex 3 of the Bank’s climate-related financial disclosure 2022.
A high-level comparison of the Bank’s net-zero target and 2030 Target is set out in Table 3.E of the Bank’s climate-related financial disclosure 2023.