Consulting services for sustainable transformation | Strategic Thinking - Milon Gupta

ESG Risk Planning for Regional Financial Institutions

From 2026/2027 onwards, financial institutions will be required under Section 26d KWG, proportionate to their complexity and size, to prepare an ESG risk plan. Savings banks, cooperative banks, and other regional financial institutions already often have initial foundations for ESG risk assessment today, for example through association templates, existing risk inventories, or internal preparatory work.

The real challenge therefore often lies not in the basic structure, but in institution-specific plausibilisation, further development, and audit-proof documentation.

I support institutions in developing existing foundations further in a regulatorily robust way and in addressing precisely those points that are typically not fully covered by association support.

These include in particular:

  • institution-specific ESG risk drivers
  • regional characteristics and concentration risks
  • transmission mechanisms into existing risk types
  • quality assurance of existing drafts
  • preparation of the plan for the executive board, internal audit, and external review

Typical use cases

My support is particularly useful for:

  • further development of existing ESG risk plan drafts
  • quality assurance of already developed content
  • proportionate implementation with limited resources in small, non-complex institutions
  • institution-specific adaptation of association templates

Typical scope of services

The support is modular and institution-specific.

Depending on need, I support in particular with:

Current-state assessment and gap analysis

  • review of existing documents
  • alignment with Section 26d KWG
  • classification in line with MaRisk and EBA guidelines
  • identification of open fields of action

Technical assessment

  • analysis of relevant ESG risk drivers
  • assessment of transmission mechanisms
  • classification of regional risk exposures
  • qualitative and simplified quantitative plausibilisation

Documentation and quality assurance

  • structuring of existing drafts
  • audit-ready documentation
  • management and board version
  • preparation for internal audit and external review

Your concrete benefit

You receive practical, independent support that complements existing association and institutional foundations and makes them institution-specifically robust.

This helps you to:

  • implement regulatory requirements effectively
  • deploy internal resources in a targeted way
  • avoid over-fulfilment
  • ensure compatibility with association logics
  • bring the quality of the plan to a supervisory-compliant level

Project logic

Support typically lasts 6–8 weeks, depending on the size of the institution, the amount of preparatory work, and the desired level of detail.

The institution retains full responsibility at all times.

I provide support as a professional sparring partner and implementation facilitator.

Pricing and approach

The required services depend heavily on the initial situation and the specific requirements of each institution. The consulting fee is based on the individually agreed-upon scope of services. I will gladly prepare a corresponding offer for you based on our initial consultation.

In the initial discussion, we jointly clarify:

  • existing foundations
  • open areas for action
  • time priorities
  • a sensible project scope

Next Step

Contact me to schedule a free initial consultation:

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