A bank that could report its own emissions while the ones that mattered stayed blank.
A mid-sized European bank had its own operational footprint under control. The lighting, the travel, the buildings: all measured, all shrinking. None of it was the point. Ninety-plus percent of a bank's emissions sit in what it lends to and invests in, and on that number the bank was close to silent. Its CSRD reporting cycle was approaching, and the financed-emissions section was a blank the auditors were not going to accept.
More than a disclosure gap. Without a financed-emissions baseline, the bank could not answer its own board on where climate risk sat in the loan book, could not price it, and could not show a regulator it understood its exposure. The sustainability team knew this. The credit and risk teams, who held the data, did not yet see it as their problem.
We spent the first weeks inside the credit risk function, well away from the sustainability office, because that is where the exposure data lived and where the resistance lived too. We worked through the PCAF methodology in detail, attributing emissions across the lending portfolio by asset class. The model was integrated into existing risk systems, avoiding a separate spreadsheet that would quickly fall out of use. Where counterparty data was missing, we agreed a documented estimation approach an assurer could follow.
The bank filed a financed-emissions figure with a method note behind every asset class, and it held up under limited assurance. The quieter outcome mattered more: the risk team now owns the number and updates it on its own cycle. It has even started asking about the carbon intensity of new lending before a loan is booked, where before the question came a year too late.