SS5/25 came into force and replaced

SS3/19 in full.


On December 3, 2025

Firms should complete an internal

review and a plan to address any gaps.


By June 3, 2026

Supervisors may ask for evidence of the

review, gap analysis and action plan.


After June 3, 2026

Key Dates

From Supervisory Expectation to Practical Response

The PRAs expectations for SS5/25 are outlined below, along with explanations of how Incol Intelligence addresses them:

PRA Requirement

PRA Requirement

PRA Requirement

  1. Establish clear board and senior management ownership of climate risk.


  1. Establish clear board and senior management ownership of climate risk.


  1. Turn climate risk into measurable metrics, limits and management information.


  1. Use scenario analysis and stress testing to support decision-making.


  1. Reflect climate risk in collateral, borrower and portfolio credit analysis.


  1. Address data gaps and apply suitable proxies where needed.



Incol's Response

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.

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 just a compliance exercise. InCol Intelligence gives management a live, decision-useful view of the mortgage book that can strengthen risk management, improve management insight and support better commercial decision-making.