The key messages are as follows:

We support the approach of the European Banking Authority to follow a risk-based and risk sensitive approach. Banks should not be used as the primary enforcers of EU climate policy, but can channel financing to sectors and business in line with public policy objectives. Those public policy objectives need to be defined by the political institutions who are in a position to define detailed transition paths. Therefore, the prudential treatment should be based on the actual financial risk posed by an exposure and not on political considerations
It is important to note that banks are already integrating environmental risks in their risk management frameworks and are collecting data from customers to that end
We support the dialogue between supervisors and banks to discuss how banks can manage and, if need be, mitigate climate risks, taking into account each banks specific situation, rather than seeking a solution through the pillar 1 framework
We also encourage that regulators and supervisors work together with banks to develop the methodologies that can include the forward-looking aspect of climate risk and long-term horizons in the risk management framework. In this respect it is important to highlight that the prudential framework already provides for means to understand where banks stand in terms of climate risk, such as scenario analysis