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Climate Change and Environment

Climate Risk and Disclosure for Companies and Lenders

Climate risk assessment, taxonomy alignment and IFRS S2-aligned disclosure for banks, insurers and companies facing CBK guidance and ICPAK's 2027 mandatory reporting.

Sector
Climate Change and Environment
Typical timeline
8 to 16 weeks
Delivery
Onsite or virtual
Deliverables
5

The problem

The Central Bank of Kenya expects banks to integrate climate-related risks into governance, strategy and risk management under its 2021 Guidance on Climate-Related Risk Management, and in April 2025 it issued the Kenyan Green Finance Taxonomy and a Climate Risk Disclosure Framework for the banking sector. ICPAK has adopted IFRS S1 and S2, making sustainability and climate disclosure mandatory for public interest entities, including listed companies, banks and insurers, for periods beginning on or after 1 January 2027, with large entities outside that category following from 2028.

Boards must therefore show how physical risks such as drought and floods, and transition risks such as carbon pricing and shifts in energy policy, affect their strategy, portfolios and financial position. Lenders and insurers also need to understand their clients' exposure, because climate risk in a loan book or underwriting portfolio is the sum of the risks carried by the businesses and households it finances. That requires Kenyan hazard and policy evidence, scenario analysis, emissions data, governance arrangements and disclosures that auditors and supervisors can test.

Policy anchors

  • Guidance on Climate-Related Risk Management (Central Bank of Kenya, 2021)
  • Kenyan Green Finance Taxonomy and Climate Risk Disclosure Framework (Central Bank of Kenya, 2025)
  • ICPAK roadmap for the adoption of IFRS S1 and IFRS S2
  • National Green Fiscal Incentives Policy Framework (Sessional Paper No. 5 of 2024)

How we work

  1. Gap assessment

    We assess current governance, strategy, risk management and disclosure against IFRS S2 and, for banks, the CBK guidance and disclosure framework. We then set a phased plan to the first reporting date.

  2. Climate risk identification

    We identify the physical and transition risks relevant to the business or loan book, drawing on Kenyan hazard data, the NDC, carbon market rules, energy policy and green fiscal measures.

  3. Scenario and portfolio analysis

    We run qualitative and, where data allow, quantitative scenario analysis, and map lending or investment exposures to the Kenyan Green Finance Taxonomy.

  4. Metrics and targets

    We define climate metrics, including greenhouse gas emissions where required, set out data sources and controls, and test them for assurance readiness.

  5. Disclosure drafting and board briefing

    We draft the disclosures and board papers, and brief directors and management on their oversight duties.

What you receive
  • IFRS S2 and CBK gap assessment with a phased implementation plan
  • Climate risk register covering physical and transition risks
  • Scenario analysis report and taxonomy alignment assessment
  • Metrics, data and controls framework
  • Draft climate-related disclosures and board briefing pack
Who it is for

Banks, mortgage finance companies, insurers, listed companies and other public interest entities, together with their boards and audit and risk committees.

Questions clients ask

When must we report under IFRS S2?

Under the ICPAK roadmap, public interest entities apply IFRS S1 and S2 for periods beginning on or after 1 January 2027, large non-public interest entities from 2028 and SMEs from 2029. Voluntary adoption has been open since 1 January 2024, and early preparation gives time to build data and controls.

We are a bank. How does the CBK framework relate to IFRS S2?

The CBK Climate Risk Disclosure Framework sets supervisory expectations for how banks identify, assess and disclose climate risks in their portfolios, while IFRS S2 governs climate disclosure in general purpose financial reports. We build one evidence base and set of controls that serves both.

Do you provide assurance on the disclosures?

No. Assurance is the role of the entity's auditor. We prepare the analysis, data controls and drafts so that assurance can proceed on a sound basis.

Climate Risk and Disclosure for Companies and Lenders

Request a proposal.

Tell us about the institution, the timeline and what you need to decide. We will reply with a proposed scope, team and timeline.

Your enquiry goes straight to our team at info@policy.co.ke, and we reply within one working day. We use your details only to respond.

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