Work out who is actually asking
before you build the plan.
Most transition plans are commissioned because someone believes a standard requires one. Usually it does not, and the real driver, a lender, a regulator, an index or a parent, determines what the plan must contain and who has to accept it.
ESGweise delivers climate risk assessment, scenario analysis and climate transition planning for banks, utilities and industrial groups across the GCC and Jordan. Work is built to the IFRS Foundation's June 2025 transition disclosure guidance, with sector detail from TPT and financing structure from GFANZ, and integrates with financed emissions measurement under PCAF and target setting under SBTi.
Naming the driver
A plan for a development finance lender, a prudential supervisor and a rating index are not the same document, and each is judged differently. If the driver was never named, the plan has no test of adequacy and gets judged on presentation.
-
01 A prudential regulator
Usually asking for climate risk management integrated into governance and the risk appetite framework, not a transition plan.
-
02 A lender or DFI
Specific, testable conditions attached to facilities, assessed by people who read the plan properly.
-
03 An index or rating
Scored against published criteria and compared with peers. The plan has to hit named elements.
-
04 A parent or shareholder
Often the most demanding audience, and the least visible from outside the group.
Four workstreams
- Climate risk assessment and scenario analysis. Physical and transition risk across the portfolio or asset base, using NGFS scenarios where the supervisor expects them.
- Financed emissions baselines. Built to the PCAF methodology, with data quality scored honestly rather than concealed. For a bank this is the schedule driver for everything downstream.
- Transition plan development. To the IFRS Foundation's June 2025 guidance, with sector detail from the TPT Banks guidance where it applies.
- Target setting. Including SBTi where that route is chosen, with the commitments tested against the book before anything is signed.
The baseline starts first
The most common scheduling error in transition planning is treating the plan as the project. Given a sound emissions baseline, the plan is quick. The baseline is not, and it cannot be shortened by adding people.
So scoping, the maturity diagnostic and the baseline run in parallel from week one, and the risk assessment runs alongside the baseline rather than after it. That is the only legitimate way to compress a programme that otherwise runs nine to fifteen months.
The other failure worth naming: a plan that never reaches the risk appetite framework changes no decisions. Board approval is a stage in its own right, and adoption into existing governance is what separates a plan from a brochure.
Current, not as-was
A good deal of published transition planning commentary describes bodies that no longer operate as they did. The Transition Plan Taskforce closed in October 2024 and its material transferred to the IFRS Foundation, which published its own guidance on 23 June 2025. GFANZ restructured in January 2025 and dropped the requirement that users align with the Paris goals.
We cite the IFRS Foundation guidance as the authority, TPT as the structure beneath it, and GFANZ for financing levers and worked examples. The frameworks were designed to be compatible, so choosing between them is rarely a real decision.
Related work sits in sustainability reporting, carbon and GHG, and our banking and financial services practice. Financial risk modelling, ICAAP and stress testing are delivered through our sister practice.
Climate Risk & Transition Planning — questions we hear most
Does IFRS S2 require us to have a transition plan?
No. IFRS S2 requires disclosure of a climate-related transition plan if the entity has one, at paragraph 14(a). It does not oblige an entity to prepare one. This is the commonest error in published commentary on the standard, and it matters commercially: if IFRS S2 is not the driver, something else is, and identifying which determines what the plan has to contain and who has to be satisfied by it.
Which framework should a transition plan be built to?
The IFRS Foundation guidance published on 23 June 2025 is the current authority. The Transition Plan Taskforce closed in October 2024 and its disclosure material transferred to the IFRS Foundation, so TPT documents remain useful as the structure beneath that guidance rather than as a standalone authority. GFANZ material is still widely used for financing levers and worked examples, though GFANZ restructured in January 2025 and should not be described as it was in 2022.
How long does a bank transition plan take?
Nine to fifteen months from a reasonable starting base. The determining factor is the financed emissions baseline, typically three to nine months, because it depends on counterparty data most banks do not hold in usable form. Everything downstream waits on it, which is why the baseline should start before the target architecture is agreed rather than after.
Do GCC and Jordanian regulators require transition plans?
Generally they require climate risk management and disclosure rather than a transition plan. CBJ Regulations No. 2 of 2025 in Jordan are a clear example: they mandate climate risk management, which is a different obligation. Requirements differ by jurisdiction and are moving, so the position should be confirmed with the relevant supervisor rather than generalised across the region.
What is the difference between climate risk management and a transition plan?
Climate risk management is inward-facing: how physical and transition risks affect the institution's own balance sheet, capital and operations, and how that is governed. A transition plan is outward-facing: what the institution intends to do about its own contribution to emissions. An organisation can have rigorous climate risk management and no transition plan and be entirely compliant. Conflating them leads to building the wrong deliverable.
Thirty minutes. We figure out if there's a fit.
We don't pitch on the call. We listen, ask sharp questions, and tell you honestly whether climate risk & transition planning is what you need — or what else might be.
Speak with our team