Financed Emissions

Swiss Climate supports you in calculating financed emissions and completing the FINMA questionnaire

Every year, Swiss banks receive a questionnaire from FINMA in which they are required to disclose financial information about their lending and investment portfolios, the associated greenhouse gas emissions, risk analyses, and the bank’s defined climate targets. The process is technically demanding and is becoming increasingly important as part of the transparency required by regulatory authorities.

The 2026 data collection must be submitted by May 31, 2026, at the latest. At the same time, expectations regarding traceability, consistency, and data quality are rising compared to the previous year.

Many institutions use the data collection as a pragmatic assessment of their current status: Where do we stand today? What data and methods are already available? And where are there gaps in processes or control logic with regard to future implementation requirements?

In this context, Swiss Climate 2025 had the opportunity to assist the Banque Cantonale de Fribourg (BCF), among others, in calculating its financed emissions and completing the FINMA questionnaire.

“In 2025, the Swiss Climate teams proved to be responsive, competent, reliable, and committed to supporting the Banque Cantonale de Fribourg (BCF) with its reporting obligations. Their effective support was greatly appreciated! The proof? Swiss Climate will support the BCF again in 2026.”

- Sandra Galliker, Sustainability Manager at the Fribourg Cantonal Bank

Our Role: A Comprehensive and Structured Approach

Swiss Climate supports you throughout the entire process—structured around three key components:

1) Calculation of financed emissions (Scope 3.15) in accordance with PCAF

• Comprehensive analysis of your portfolio data across key asset classes (including mortgages, corporate loans, and financial investments).
• Efficient, pragmatic data collection and preparation—tailored to your system landscape and resources.
• Plausibility checks and application of the current PCAF methodology (as of 2025).
• Determination of the carbon footprint per asset class—with transparent documentation of all assumptions.
• Reporting based on best-practice metrics – aligned with FINMA expectations and PCAF recommendations.

If you have already calculated the financed emissions internally, we support you with quality assurance (Assurance) based on the PCAF standard and in accordance with FINMA requirements.

2) Closing data gaps and improving data quality in a targeted manner

A recurring challenge for financial institutions is the availability and quality of financial, technical, and emissions data.

We support you in achieving rapid results with a realistic improvement plan:

• Identification of data gaps and their impact on the quality of results and FINMA reporting.
• Concrete strategies for gradually closing these gaps (short-, medium-, and long-term).
• Traceable assumptions for missing data—including transparent derivation and justification.
• Harmonization of system boundaries, assumptions, emission factors, and reporting logic—for consistent comparability over the years.

3) FINMA Questionnaire: Efficient, Consistent, and Verifiable

The FINMA questionnaire quickly becomes complex—especially when quantitative results, qualitative statements, and methodological explanations must be consistently integrated.

We support you with the following measures:

• Interpretation of FINMA expectations and translation into clearly actionable steps.
• Preparation of quantitative responses (emissions, intensities, coverage, durations, sector exposures).
• Consolidation of qualitative sections (risk management, targets, scenarios).
• Identification of improvement potential for subsequent years and prioritization based on effort/impact.
• Knowledge transfer so that you can efficiently repeat the process internally in the future.

Your Added Value with Swiss Climate

With Swiss Climate, you benefit from comprehensive support that offers you, among other things, the following:

• Significant time savings thanks to proven methodology and direct access to our experts in CO₂ management and sustainability. Swiss Climate has expertise across all asset classes and guides you step by step through the process.
• Pragmatic implementation: We combine strategy, data, and regulation—and make requirements operationally feasible.
• Greater certainty: Precise interpretation of FINMA requirements and clean, traceable documentation in accordance with recognized standards (PCAF).
• Better data—year after year: Concrete recommendations tailored to your specific circumstances.
• Outlook on regulatory developments in a dynamic environment.

This offering is aimed at banks, insurance companies, pension funds, and other financial institutions that wish to ensure the accuracy of their reporting, reduce internal administrative burdens, or improve the quality and precision of their data on financed issuances.

Would you like to learn more?

If you have any questions or would like to discuss potential support, Eva Nenninger is happy to assist you.

 

Picture: Scott Graham (Unsplash)

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