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Understanding transition risk in financial services
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Published: 5 August 2026
Author: Max Finney

What is climate scenario modelling – and why use it?

Climate scenario modelling is about making better decisions in uncertainty. It helps organisations understand how different policy, market and technology pathways could shape their operations and long‑term strategy. Instead of betting on a single forecast, it tests a range of credible futures—so leadership teams can challenge assumptions, pressure‑test investments and strengthen resilience where it matters most.

This matters because expectations have shifted. Regulators increasingly require organisations to assess and disclose climate‑related risk. But this goes beyond compliance. Investors, regulators and wider society want clear evidence that organisations understand their exposure and are actively building more resilient businesses and supply chains in response.

Our scenario analysis draws on work undertaken by external consultants as part of Shoosmiths’ Transition Risk Assessment and uses the European Sustainability Reporting Standards (ESRS) impacts, risks and opportunities (IRO) framework to identify the sustainability themes most relevant to our key client sectors. The high priority themes were then tested against three future climate pathways from the Climate Change Committee (CCC), reflecting different levels of policy intervention, behavioural change and progress towards net zero.

For each sector, the analysis considered how risks and opportunities could evolve under each scenario, examining implications across areas such as regulation, markets, technology, investment, operations and reputation. This helps to ensure the analysis reflects the sustainability issues most likely to shape future business performance, stakeholder expectations and legal demand. We are therefore able to use the results to turn abstract risk into practical insight that mobility, logistics and manufacturing leaders can act on.

The three scenarios used

1. Business as Usual (BAU)

No major policy changes beyond current commitments. This represents the slowest pace of decarbonisation and the highest level of sustained climate risk.


2. Moderate Ambition

Some policy progress, but behaviour change and infrastructure deployment lag behind net zero pathways.


3. 1.5°C Aligned (Balanced Pathway)

Policy and behaviour change keep pace with net zero goals. This scenario delivers the most resilient and lowest‑carbon future.

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What are the material transition risks and opportunities for financial services?

Our scenario analysis highlights several critical impacts of the transition to net zero across markets, technology, policy and consumer dynamics. These evolve over time and present both challenges and opportunities.

Short term (to 2030)

Key risks

  • energy cost volatility: Continued reliance on fossil fuels keeps energy costs high in Business as Usual and Moderate Ambition scenarios, raising operational costs across digital infrastructure and financial institutions. For financial services, sustained energy volatility directly affects the cost base of offices, trading floors and data‑intensive activities such as payments processing, cloud services and AI‑enabled analytics
  • infrastructure constraints: Power grid capacity and water stress risks limiting the growth of data centres, slowing the deployment of digital finance and AI‑driven services. This creates a material risk for financial services firms that rely on secure, scalable digital infrastructure to deliver core services, manage risk models and meet client expectations
  • climate‑related disruption: More frequent storms and heatwaves cause outages to energy, transport and digital systems, affecting financial system resilience. For banks, insurers and asset managers, this increases operational resilience risk and can disrupt service continuity, transaction processing and client access
  • reputational pressure: Slower decarbonisation damages the UK's standing as a global green finance centre. Financial services firms face heightened reputational and conduct risk if clients, investors or regulators perceive misalignment with net zero ambitions.

Opportunities

  • early investment in nature‑based solutions, digital resilience and AI for climate analytics creates opportunities to develop new advisory services, financing products and risk tools that support clients’ transition plans
  • growing demand for sustainable finance instruments and climate‑aligned investment products supports revenue growth in areas such as green bonds, transition finance, sustainability‑linked lending and climate‑focused funds.
Medium term (to 2040)

Key risks

  • misaligned investment flows: Delays in grid upgrades and sustained fossil fuel infrastructure shift capital away from the UK. This increases market and portfolio risk as capital reallocates across geographies and sectors perceived as more transition‑ready
  • regulatory tightening: More stringent disclosure and transition planning requirements increase operational and legal risk for firms slow to adapt. Greater scrutiny of governance, climate claims and fiduciary duties linked to climate‑related financial risk create additional administrative burden and exposure to fines and enforcement for non-compliance
  • technology bottlenecks: Without rapid electrification, both BAU and Moderate Ambition scenarios limit fintech growth and reduce competitiveness. This constrains innovation in financial services, particularly in digital payments, data‑driven credit assessment and AI‑enabled compliance tools
  • water scarcity: Competition for water between housing, industry and digital infrastructure constrains development in all sectors. This translates into location risk for data centres and increased due diligence requirements on financed assets, increasing the burden of administration and therefore timelines of deals.

Opportunities

  • financial innovation to support hydrogen, carbon capture, battery recycling and critical minerals markets. Those firms that are well placed to structure, finance and insure the infrastructure and technologies required for a net zero economy stand to gain significant market share and revenue
  • client demand for transition planning, portfolio decarbonisation and climate risk advisory services strengthens the strategic role of financial services as enablers of credible transition pathways across the real economy
Long term (to 2050)

Key risks

  • systemic market disruption: In BAU, sustained vulnerability across energy, transport and water systems affects asset values, risk modelling and lending decisions. This raises systemic financial risk and challenges traditional approaches to credit, insurance pricing and capital allocation. Disruption to established processes result in exposure to volatile markets and increased cost for development of new models
  • digital inequality: Rapid digitalisation without resilience measures risks excluding vulnerable groups and exposing them to cyber threats. Conduct, consumer duty and reputational risks for financial services providers increase exponentially reliant on digital‑first delivery models
  • stranded assets: Retained fossil fuel infrastructure increases long‑term exposure to devaluation and transition cost shocks. Banks, insurers and investors face heightened balance sheet risk if transition exposure is not actively managed.

Long‑term opportunities

  • a fully decarbonised grid in the 1.5°C scenario reduces energy prices and unlocks scalable deployment of data‑centric financial services. Long‑term operational resilience and growth in digital, data‑intensive financial products supports operation resilience and investment opportunities
  • mature supply chains for renewables, battery technology and natural capital markets create new investment avenues, with financial services playing a central role in mobilising capital and shaping these emerging markets
  • inclusive and just‑transition strategies strengthen customer trust and market resilience through a wider, more diverse range of participants in the economy, increasing the pool of talent for firms to recruit from and investment opportunities in entrepreneurs and SMEs

How risks and opportunities vary across the three climate scenarios

THEME
BUSINESS AS USUAL
MODERATE AMBITION
1.5°C ALIGNED
Energy

High and volatile power prices driven by continued fossil fuel reliance increase operating costs for business.

Grid constraints limit data centre expansion, slowing AI, cloud migration and fintech innovation.

Partial grid decarbonisation reduces some volatility but continued gas reliance keeps prices elevated.

Data centre growth constrained in some regions, creating uneven access to digital capacity.

Fully decarbonised, resilient grid delivers more stable energy prices.

Scalable, low carbon power enables data centre expansion, advanced analytics, AI deployment.

Technology

Limited data centre capacity and infrastructure disruption from extreme weather reduce system resilience.

Slower AI adoption constrains risk modelling, climate analytics and innovation.

Regional disparities in digital infrastructure persist, limiting rollout of digital innovations.

Improved but uneven digital infrastructure supports growth in core systems, but power and water constraints limit advanced AI use.

Cyber resilience and redundancy require higher ongoing investment due to extreme weather and uneven policy implementation.

Reliable, low carbon digital infrastructure supports widespread AI, real time climate risk assessment and fintech growth.

Higher system resilience reduces outage risk and improves customer trust and adoption.

Policy and Legal

Weak and inconsistent policy signals reduce investor confidence in UK sustainable finance.

Regulatory change is reactive and frequent, increasing compliance complexity and cost without clear long-term direction.

Clearer direction than BAU but continued policy uncertainty increases regulatory burden.

Firms face overlapping reporting, transition planning and supervisory expectations across regimes.

Increase in transparency requirements exposes firms to increased stakeholder pressure and reputational risk.

Clear, stable and credible policy framework aligned to net zero supports long term capital allocation.

Strong cross-border regulatory certainty accelerates green finance, transition products and innovation.

Significant increase in transparency and compliance requirements result in potential cost to do business, despite assumed AI efficiency gains.

Reputation

UK loses leadership position as a global green finance centre.

Firms face reputational risk from perceived misalignment with climate goals and reduced international competitiveness.

Reputation risks remain if progress is seen as too slow or inconsistent.

Competitive pressure increases from jurisdictions with clearer net zero delivery.

Reputation strengthened through credible net zero alignment, resilient infrastructure and leadership in sustainable and transition finance, reinforcing the UK’s global standing as a global hub for green finance.
Communities and Consumers
Higher energy and insurance costs disproportionately affect vulnerable customers, increasing credit, affordability and conduct risks for financial institutions.

Faster change creates transition risk for some customers and SMEs if support mechanisms lag.

Financial inclusion challenges persist for digitally excluded groups.

More inclusive transition supported by coordinated policy and investment.

Lower system costs and better digital access improve financial inclusion and resilience for households and businesses.

What this means for financial services leaders

Climate transition risk has deep implications for capital allocation, operational resilience, digital strategy and consumer outcomes across financial services. For GCs, sustainability heads and leaders across the business, scenario analysis is becoming more than a reporting exercise, it is a strategic tool to understand potential futures and ensure the business is fit for purpose beyond the next reporting cycle.

Organisations can use scenario analysis for a host of reasons including, but not limited too:

Within financial services, transition risk is generally more advanced than in many other sectors, a development largely attributed to legislation like TCFD. Yet, despite this progress, actions remain insufficient; global financed emissions continue to rise even as investment intensity decreases. As regulators increasingly demand credible transition pathways instead of simply setting long-term targets, investors and NGOs are paying closer attention to the gap between stated commitments and actual capital flows. The risks linked to litigation, greenwashing, and fiduciary duty are escalating when disclosures and strategies fail to align, making it more important than ever for institutions to ensure consistency. Moreover, trends in financed emissions now directly influence transition risk assessments, stress testing, and capital adequacy discussions, reflecting their growing significance in the industry.

Given the increased scrutiny on transition risk, scenario analysis emerges as a critical strategic tool for financial services leaders. By systematically exploring a range of possible futures, organisations can proactively identify and mitigate the risks of higher costs, reduced access for vulnerable groups, and operational disruption during periods of rapid change. Considering the volatility of the geopolitical situation in many regions, this more fluid approach enables firms to take a more holistic and balanced approach to climate risks and opportunities.  This approach not only supports compliance with regulatory demands for credible transition plans, but also enables firms to align their capital allocation and operational strategies with a more inclusive and resilient transition, thereby reducing exposure to litigation and reputational damage from greenwashing or unfulfilled commitments.