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Regulator BriefingSupervisory GuidanceVol. 02 · Issue 01

The RBI Draft Framework on Climate Risk — a supervisory read-through

What the Reserve Bank of India's climate-risk disclosure guidance actually asks of banks — and where the gap sits between policy intent and portfolio reality.

Type
Regulator Briefing
Read Time
12 minutes
Author
The Carbonis Research Desk
Focus
Supervisory Guidance
Abstract

The RBI's Draft Disclosure Framework on Climate-Related Financial Risks is not another disclosure template. It is a supervisory-review instrument. This briefing decodes what a board-approved climate risk strategy actually looks like when a JPC walks in — and why most Indian banks are not yet 12 months from being ready.

01— What the framework asks

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."

02— Where the gap sits

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?
24 months
typical remediation window from draft to enforceable framework
3 layers
board · risk committee · supervisor — must give consistent answers
PCAF v2
the financed-emission methodology now supervisor-tracked
40–90 bps
COC uplift already modelled by leading Indian PSBs on high-intensity borrowers
03— What Carbonis does

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.

Prepared By
The Carbonis Research Desk
Climate Risk Infrastructure
Next Resource

The MSME Climate Playbook — from first inventory to first delisted competitor

A practical field guide for Indian MSME founders and CFOs preparing for CBAM, buyer Scope 3 KPIs, and the coming credit-risk repricing.

The Next Step

Get carbon risk off your P&L — while there is still time.

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