Regulatory tracker
Dated PRA changes that affect a UK bank's risk function, with a link to the source for each, updated on the first working day of each month.
RiskTAERisk Talent · Executive search
Which senior manager holds climate risk decides what a head of climate risk does: under the chief risk officer the role has a claim on the credit models and the stress test; under the chief financial officer it is a reporting role. RiskTAE runs retained searches for heads of climate risk in UK banks, building societies, investment firms and insurers.
A partner runs the search from the written brief to the first day, and every candidate is interviewed on the technical substance of the role before you see a CV.
You meet people who can get climate risk into the ICAAP, the stress tests and the risk appetite statement, rather than into a report the board reads once.
By Benn PopleUpdated
The role
The head of climate risk runs the second line for climate-related risk: finding it inside the credit, market, liquidity and operational risk the firm already carries, and getting it into the ICAAP, the internal stress tests and the limits in the risk appetite statement. The PRA’s SS5/25 came into force on 3 December 2025, replaced SS3/19 in its entirety, and applies to banks, building societies, PRA-designated investment firms and insurers.
SS5/25 expects boards and executives to assign individual responsibility for identifying, assessing and managing climate-related risks at an appropriate level of seniority, for example to an existing senior management function, shown in that person’s statement of responsibilities. In most banks that is the chief risk officer, who holds the PRA’s Chief Risk function, SMF4, and the head of climate risk reports to them.
The first thing we settle in a brief is which senior manager carries that responsibility, because it changes the job. Under the CRO, the role has a claim on the credit models and the stress test. Under the chief financial officer, because disclosure got there first, it is a reporting role, and candidates who suit one turn down the other.
Sources: PRA SS5/25, 3 December 2025, paragraphs 3.1 and 4.6; PRA PS25/25, 3 December 2025, paragraphs 1.1 and 1.7; PRA Rulebook, Senior Management Functions Part, rule 3.4.
Candidates
From four places. Heads of climate risk at other banks and insurers who have run a full scenario cycle and written the climate chapter of an ICAAP. Credit risk and stress testing specialists who did the climate work inside a larger function and want to lead it. Sustainability and ESG leaders from the first line or finance, who know the disclosure standards but have rarely defended a number to a risk committee. And consultants and former supervisors, who know the standard but have not run a function.
Two tests matter most. Whether the person can get climate into a model: we ask which of their last firm’s credit or pricing models changed because of their work, and what the ICAAP said about climate capital as a result; many ran a scenario exercise that changed nothing. And whether they can argue with a head of credit about a sector concentration limit and win.
Scale is the mismatch we see most: in a large bank the head of climate risk runs a team and borrows a modelling function; in a smaller bank one person must persuade the credit and stress testing teams to lend theirs. The interviewers have held these roles, former chief risk officers and heads of risk, former regulators and interim executives, with model and quant specialists for the scenario work.
Process
| Stage | What happens | What is different for this role |
|---|---|---|
| Brief | A 30-minute call, then a written brief: the role, first-year success, terms and timetable. | Which senior manager’s statement of responsibilities carries climate risk, whether the role is a certification function, and who owns the stress test. |
| Market map | The people who fit, most not looking, approached in confidence without naming you. | Built across banks and insurers, because SS5/25 covers both and the scenario skills travel. |
| Technical screen | Each candidate is interviewed on the substance before you see a CV. | On scenario analysis, the ICAAP chapter and the appetite statement, by people who have held the roles. |
| Shortlist | A short list with our written view of each person, then interviews and feedback both ways. | The CRO and the chair of the risk committee meet the final two and hear each present their reading of the firm’s exposure. |
| Offer, checks and start | We handle the offer, plan the checks and stay close through notice and the first months. | Regulatory references over six years apply to this role too; our guide to regulatory references after PS12/26 sets out the timetable. The PRA expects a criminal record check for non-SMF holders, with the candidate’s consent. |
Sources: PRA Rulebook, Fitness and Propriety Part, rule 2.7; PRA SS28/15, April 2026, paragraphs 4.19, 6.4 and 6.5; PRA PS12/26, 22 April 2026, paragraph 2.79.
The regulator’s timetable
Usually not. Neither regulator’s list of senior management functions for a bank names climate risk, and SS5/25 points to existing ones for the responsibility, so in most firms the role is a certification function: the firm certifies each year that the person is fit and proper, rather than the regulator approving them.
Approval is needed where the head of climate risk also performs the Chief Risk function, SMF4, or holds overall responsibility for an area with no other approval (the FCA’s SMF18). The regulator then has three months from a properly completed application, and the clock stops whenever it asks for more information.
Approval or not, the statement of responsibilities needs doing on day one. If the hire moves climate risk from one senior manager to another, two statements change, and the PRA expects a revised statement within six months of a significant change. Until then the new head has no mandate the supervisor recognises.
Sources: FCA Handbook, SUP 10C.7.1R and SUP 10C.10; PRA Rulebook, Certification Part, rules 2.1 and 2.2, and Allocation of Responsibilities Part, rules 2.1 to 2.4; PRA SS28/15, April 2026, paragraph 2.54; PRA SS5/25, paragraph 4.6.
Failure points
Sources: PRA SS5/25, 3 December 2025, paragraphs 3.2, 3.3 and 4.6; PRA Rulebook, Allocation of Responsibilities Part, rule 4.1(11).
Working with your team
The chief risk officer owns this hire. Where the CRO role is open too we run the two searches together (see chief risk officer search), and for a brief that covers the whole framework rather than climate alone, see enterprise risk leadership search. The chair of the risk committee, whom the PRA holds responsible for safeguarding the independence of the risk function, usually meets the final candidate.
HR, in-house talent acquisition and RPO teams own the process and the offer; we bring the senior risk market map and the technical screen, for one hard-to-fill role or a whole programme (see talent acquisition teams).
The same firm does advisory, consulting and training, so a search can be paired with interim cover on the climate chapter of the ICAAP through Risk Advisory, or with board risk training for the committee the new head will present to. The rest of our searches are listed under Risk Talent.
Source: PRA SS5/16, July 2018, paragraph 4.3.
FAQ
Yes, where the role is a risk role: a second-line function that identifies, assesses and manages environmental and social risks and reports to a risk committee. Where the brief is sustainability reporting or disclosure, we say so on the first call; our people are risk practitioners and another firm would run that search better.
Yes. SS5/25 applies to insurers as well as banks, and the scenario and appetite skills travel between them, so our market map covers both. We also search for international clients.
Book a confidential career call, message us on WhatsApp on +44 7537 159269 or email talent@risktae.com. Roles at this level are rarely advertised, so we approach people directly, and we never put your name forward without your agreement.
Insights
Dated PRA changes that affect a UK bank's risk function, with a link to the source for each, updated on the first working day of each month.
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In 30 minutes we will agree the brief, say how the market is likely to read it and tell you whether a retained search is the right route.
Tell us about the role and a partner will come back to you. Treated in confidence.
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