Ideally, the process should be evidence-driven from the outset, both in terms of the science and the economics of climate change. You need to understand the potential impact of climate- and sustainability-related issues on investments within your jurisdiction, including the financial and social costs of failing to deal with climate risks.
A sharp focus on transition risks is also important. As more governments and investors make net-zero pledges, we can expect to see the roll-out of concrete climate policies to steer the economy towards net-zero. Expectations around carbon pricing and trading will also be a major driver for the disclosure of transition scenarios.
At the early stage, regulators should consider how to leverage the regulatory tools currently available to them so that climate risk can be addressed as a financial risk. They can then look at how the introduction of climate- or sustainability-specific rules could provide more transparency and improve investment-management practices in this area.
Important issues around investor protection will also need to be addressed, particularly those stemming from greenwashing. Regulators should set clear expectations for sustainability-related disclosures by asset managers and for green and sustainable investment products.