ShareAction supports the PRA's intention to update and clarify its supervisory expectations in light of growing climate-related risks, and welcomes the PRA's aim to build on lessons learnt in the UK and internationally over the last five years on firms’ management of climate-related risks.

Overall, we welcome the updated provisions set out in the consultation, but call on the PRA to go further and:

• Adopt a precautionary systemic risk approach to avoid the build-up of climate-related risks in the first place;
• Take micro and macroprudential measures to ensure that individual banks and insurers, and the financial sector as a whole, are better equipped to deal with such risks;
• Implement robust enforcement measures, including financial penalties if needed; and
• Better align its practices with international and EU standards