Monitoring, review, and update of the plans
Institutions should monitor the implementation of their plans using monitoring processes and metrics in line with Section 5.7 and Section 6.3.4. Institutions should perform regular projections to assess their ability to achieve their targets.
The monitoring framework should allow the management body to simultaneously track how ESG risk monitoring metrics evolve and the progress achieved towards the plan’s milestones, with a clear and detailed rationale behind missed targets or objectives, and evaluations of the potential impact on different types of financial risks for different time horizons.
Institutions should regularly, and at least every time they update their business strategy in accordance with Article 76(1) of Directive 2013/36/EU, review and, where needed, update their plans, taking into account updated information such as new materiality assessments of ESG risks, developments in their portfolios and counterparties’ activities, new available scenarios, benchmarks or sectoral pathways, and impacts of current or upcoming regulation.