CBJ Regulation No. 2 of 2025 Article 11 gave Jordanian banks six months, to around 18 August 2025, to file a climate governance structure and amended risk strategy.
Introduction
Most of Jordan’s CBJ Climate Risk Management Regulations No. 2 of 2025 sets out ongoing obligations. Article 11 was different. It set a single, dated deadline: two submissions to the Central Bank within six months. That deadline fell around 18 August 2025, and it has now passed. This article explains exactly what Article 11 required, the two supervisory tracks it created, and why it still matters for any bank that treated it lightly.
Two submissions, one deadline
Article 11 required banks to file two things with the Central Bank within six months of the regulation’s issuance on 18 February 2025. The first was about governance structure. The second was an amended risk-management strategy that integrates climate risk, with a report of the amendments made. Together, these two submissions were designed to give the Central Bank an early, concrete view of how each bank was operationalising the regulation.
The two tracks
Article 11 did not treat all banks the same on the governance-structure submission. It created two tracks, keyed to whether a bank is a domestic systemically important bank (D-SIB).
| Track | Governance-structure submission | Risk-strategy submission |
|---|---|---|
| D-SIB | Establish a dedicated climate-risk unit, division or task force in Risk Management, and submit staff names and qualifications | Amend the risk-management strategy to integrate climate risk and report the changes |
| Non-D-SIB | Submit the procedures and structure the bank will adopt (a dedicated unit is encouraged, not required) | Amend the risk-management strategy to integrate climate risk and report the changes |
The dedicated-unit requirement comes from Article 4(c), which makes the unit mandatory for D-SIBs and encouraged for other banks. A non-D-SIB may distribute climate-risk functions within Risk Management as it sees fit, but it still had to describe that structure to the Central Bank.
Why it still matters
A dated deadline that has passed can feel like history. It is not. The Article 11 submissions became part of each bank’s live compliance baseline with the Central Bank, and the supervisor assesses performance against them. A bank that filed a thin or purely formal structure and strategy has not really met the requirement, it has only recorded an intention. The rest of Regulation No. 2 of 2025, covered in our overview of the mandatory regime, is continuous and has no end date, so the substance behind the Article 11 filing has to be real and maintained.
Article 11 was a deadline for paper. The regulation behind it is a standard for practice. Meeting the first without the second satisfies nobody, least of all the supervisor.
From filing to function
The useful way to read Article 11 now is as a checkpoint, not a finish line. A bank should be able to answer three questions. Does the climate-risk structure it described actually operate, with clear ownership and resources? Does the amended risk strategy genuinely change decisions, or only documents? And is the bank ready for the next layer, external IFRS S2 disclosure, which the Amman Stock Exchange makes mandatory for ASE20 banks from FY2026? A strong Article 11 response is the foundation for that disclosure.
How ESGweise helps
ESGweise helps banks turn an Article 11 filing into a working climate-risk function. We review the structure and the amended strategy against the regulation, strengthen the risk-appetite and risk-management integration, and connect it forward to the disclosure requirements that follow. We work as an advisory partner, not a supervisor or auditor. See our strategy and assurance readiness services and our work with banking and financial services.
Conclusion
Article 11 gave Jordanian banks six months, to around 18 August 2025, to file a climate governance structure and an amended risk-management strategy, on two tracks split by D-SIB status. The deadline has passed, but the obligation behind it endures. For any bank, the question is no longer whether it filed on time, but whether what it filed describes something real, and whether that foundation is strong enough for the disclosure requirements now arriving.
Frequently asked questions
What did Article 11 of the CBJ climate regulation require?
Article 11 required two submissions to the Central Bank of Jordan within six months of the regulation being issued. First, on governance structure: D-SIBs had to establish a dedicated climate-risk unit in Risk Management and submit the names and qualifications of its staff, while other banks had to submit the procedures and structure they would adopt. Second, all banks had to amend their risk-management strategy to integrate climate risk and report the amendments made.
When was the Article 11 deadline?
The regulation took effect on 18 February 2025, and Article 11 gave banks six months to comply, which placed the deadline at around 18 August 2025. That deadline has now passed, so the submissions form part of each bank's live compliance record with the Central Bank.
What is the difference between the D-SIB and non-D-SIB tracks?
The distinction turns on whether a bank is a domestic systemically important bank. Under Article 4(c), D-SIBs must establish a dedicated climate-risk unit, division or task force within Risk Management, and under Article 11 they had to submit staff names and qualifications. Non-D-SIB banks were encouraged rather than required to set up a dedicated unit, and could instead distribute climate-risk functions within Risk Management, submitting the procedures and structure they adopted.
Does a bank still need to act if it missed the Article 11 deadline?
Yes. The obligation did not lapse with the date. A bank that has not submitted, or that submitted a thin structure and strategy, still needs to meet the substance of the requirement, because the Central Bank supervises against it on an ongoing basis. The rest of the regulation, on governance, strategy, controls and risk-management integration, is continuous and does not have an end date.