DK-Response to the consultation on Joint ESAs Guidelines on integrating ESG risks in super

in supervisory stress testing

German Banking Industry Committee Banking supervision

Dr. Teo Geldner

The German Banking Industry Committee (DK) welcomes the ESAs’ initiative to establish consistent and long-term integration of ESG risks into supervisory stress testing. While the overarching goals are appropriate, we stress the need for a proportionate and risk-based approach across all elements.

GBIC Response consultation Joint GL on integrating ESG stress test

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19.09.2025

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Dr. Teo Geldner

Banking Supervision and Accounting

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