ESG Enforcement Tracker

Key facts:

The ECB has fined Crédit Agricole €7,551,050 in periodic penalty payments for failing to conduct a materiality assessment of its climate and environmental risks.

The requirement to conduct such an assessment was laid down in the ECB decision of 8 February 2024. The bank had to reinforce its identification of material climate and environmental risks to which it was, or might have been, exposed, by the deadline of 31 May 2024. In response to Crédit Agricole’s failure to meet the requirement for 75 days, the ECB decided to impose periodic penalty payments.

The decision is part of the ECB’s escalation process to force banks to identify, assess and manage climate and environmental risks. After the publication of its ‘Guide on climate-related and environmental risks’ in 2020, which explained how banks should manage and disclose risks, in 2022 ECB conducted a climate risk stress test and identified failures. All significant institutions were provided with tailored deadlines for managing climate risks in view of the expectations. In cases where the deadlines were missed, the ECB imposed binding requirements enforceable with periodic penalty payment measures, which increase with each day of non-compliance. In addition to time, the ECB also considers the materiality of the breach and the bank’s daily turnover to calculate the fines. In November 2025, the ECB imposed a fine of €187,650 on the Spanish bank Abanca for not identifying and disclosing climate risks on time.

Crédit Agricole expressed “incomprehension” at the fine, saying it had missed the deadline owing to the extensive work required to respond to the ESB in the requisite detail, and stating that climate and environmental risks are taken into account in the bank’s models. The bank has the option to challenge the decision before the Court of Justice of the European Union.