Four asks, one supervisory intent
The RBI's draft framework rests on four pillars: governance, strategy, risk management, and metrics & targets. Each pillar is written in TCFD grammar — but read as supervisory ammunition. A board that cannot describe how its climate risk appetite is set, calibrated, and challenged is a board that will not survive the first thematic review.
"The framework does not ask you to have low emissions. It asks you to have a defensible answer for how your portfolio behaves when other people don't."
Three questions most Indian banks cannot yet answer
- — What is the financed-emission attribution of your top 25 borrower groups, using a PCAF-compliant methodology, refreshed quarterly?
- — What is your CBAM-exposed portfolio? Not sector-tagged — verified, at the borrower level, with a documented exposure heatmap?
- — How does your ICAAP treat a 40-90 bps COC uplift on high-intensity corporates, and what is the scenario governance around that assumption?
The read-only overlay for supervisory readiness
Carbonis operates as a read-only intelligence layer above your core banking systems. It ingests borrower-level exposure, applies PCAF-aligned attribution, produces a portfolio-level heatmap, and exports supervisor-grade dossiers on demand. No data migration. No integration. No workflow disruption. The bank retains its systems of record; Carbonis produces the answer the framework asks for.
