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U.S. Regulators Withdraw Climate Risk Management Guidelines for Banks

10/17/2025, 4:16:05 AM

Regulatory Changes in Climate Risk Management

On October 16, 2025, U.S. bank regulators, including the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC), announced the withdrawal of previously established guidelines for managing climate-related financial risks. These guidelines, which were introduced in October 2023, mandated that banks assess potential losses from climate-related events. The regulators now argue that existing safety and soundness standards sufficiently cover these risks, rendering the climate-specific guidelines unnecessary.

Official Statements & Responses

In a joint statement, the regulatory agencies emphasized that their current supervisory standards require financial institutions to maintain effective risk management practices appropriate to their size and complexity. Michelle Bowman, vice chair for supervision at the Federal Reserve, supported the decision, stating that the rescission would refocus supervisory processes on material financial risks. Conversely, Fed Governor Michael Barr criticized the move as "short-sighted," warning that it could increase systemic risk as climate-related financial threats become more pronounced.

Criticism & Opposition

The decision to rescind the climate risk guidelines has drawn criticism from various quarters. Barr's dissent highlights concerns that the financial system may become more vulnerable without explicit climate risk management protocols. Additionally, former Fed officials and environmental advocates have expressed apprehension that the withdrawal reflects a broader trend of diminishing regulatory focus on climate change under the Trump administration, which has been accused of "mission creep" in its approach to financial regulation.

Broader Context: California's Climate Disclosure Regulations

In contrast to the federal withdrawal, California is advancing its climate disclosure regulations. The California Air Resources Board (CARB) has delayed the implementation of new climate-reporting rules, originally set for October 2025, to early 2026. These regulations, SB 253 and SB 261, require large companies operating in California to disclose their greenhouse gas emissions and climate-related financial risks. CARB's preliminary list includes over 4,000 companies that may be subject to these new requirements, indicating a significant regulatory push at the state level.

What's Next

As the federal government steps back from climate risk management guidelines, California's regulatory framework continues to evolve. The first climate-related risk reports under SB 261 are due by January 1, 2026, while Scope 1 and 2 emissions disclosures are set to begin in June 2026. The contrasting approaches between federal and state regulators may lead to a complex compliance landscape for businesses operating across jurisdictions.

Conflicting Reports & Gaps

While federal regulators assert that existing standards are adequate, critics argue that the absence of specific climate risk guidelines could leave financial institutions ill-prepared for future climate-related challenges. The ongoing debate underscores the need for clarity and consistency in regulatory frameworks addressing climate change across different levels of government.