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SS5/25 came into force and replaced

SS3/19 in full.


On December 3, 2025

Firms were expected to complete an internal review of their position against the updated expectations, identify areas requiring further work and develop a credible and ambitious plan to address identified gaps.

By June 3, 2026

Supervisors may ask firms to provide evidence of their internal review, gap analysis, action plan and progress towards meeting the updated expectations.

After June 3, 2026

Key Dates

From Supervisory Expectation to Practical Response

SS5/25 sets broad expectations for how firms identify, assess, manage and evidence climate-related financial risk. For mortgage lenders, the challenge is translating those expectations into consistent, loan-level evidence across the portfolio.

PRA Requirement

PRA Requirement

PRA Requirement

  1. Governance and ownership
    Boards and executive management should understand material climate-related risks and incorporate them into business strategy, oversight and risk appetite.

  2. Risk appetite, metrics and management information
    Firms should translate material climate-related risks into appropriate metrics, limits, monitoring and regular management reporting.

  3. Climate scenario analysis
    Scenario analysis should be used to identify, quantify and manage climate-related risks and to inform decision-making and risk appetite.

  4. Credit and collateral risk
    Firms should identify, measure and monitor how physical and transition risks affect credit risk, including individual exposures, collateral and concentrations.

  5. Data quality and data gaps
    Firms should identify significant data gaps, maintain appropriate risk-data aggregation capabilities and document the use of proxies or assumptions where reliable data are unavailable.

  6. Evidence and reporting
    Climate-related risk information should support regular internal reporting, Board oversight, regulatory engagement and relevant disclosures.

Incol's Response

Incol's Response

  1. Loan-level exposure analysis
    Identifies physical and transition risk exposures, concentrations and outliers at individual-loan and portfolio level.

  2. Repeatable management information
    Produces consistent Board, committee and management reporting from the same validated loan-level data.

  3. Scenario-based analysis
    Combines climate scenarios with credit, collateral and property information to support scenario analysis, sensitivity testing and management discussion.

  4. Credit and collateral integration
    Brings climate risk together with LTV, valuation, EPC, affordability and other lending information so the interaction between climate, borrower and collateral risk can be assessed.

  5. Data quality and enrichment
    Identifies missing or inconsistent information and enriches the portfolio with relevant independent property, valuation and climate datasets.

  6. Traceability and evidence
    Maintains a clear trail from portfolio conclusions back to the underlying loans, source data and analytical inputs, making outputs easier to review, reproduce and explain.

Incol's Response

  1. Identifies exposures and concentrations at loan, postcode levels.


  1. Produces repeatable board, committee and management reporting.


  1. Creates a push-button supervisory view across climate, credit, collateral and concentration risk.


  1. Supports climate-adjusted credit, collateral, ECL, stress testing and ICAAP discussions with a clear evidence trail.


  1. Enriches loan and collateral data with relevant third-party and public climate datasets.


  1. Documents where proxies are applied and how conclusions have been reached.

Why It Matters

This is not simply a regulatory reporting exercise. InCol Intelligence brings climate risk into the same loan-level view as credit, collateral, valuation and affordability, helping management understand where risks are concentrated, how they interact and what is driving the outcome.

The result is a more consistent evidence base for risk management, Board and committee reporting, scenario analysis, ICAAP discussions and regulatory engagement.