On 13 February 2026, the European Central Bank (ECB) announced the imposition of periodic penalty payments, amounting to €7,551,050, on Crédit Agricole, S.A., a credit institution headquartered in France.
The periodic penalty payments were imposed in relation to Crédit Agricole’s failure to comply with a requirement in a specific ECB decision addressed to the bank dated 8 February 2026. The ECB decision had required Crédit Agricole to conduct a materiality assessment of its climate-related and environmental (C&E) risks by a specific date. Under the materiality assessment, Crédit Agricole was required to reinforce its identification of the material C&E risks to which it is, or might be, exposed. Crédit Agricole failed to comply with the requirement to properly conduct the materiality assessment as specifically required in the ECB decision for 75 days.
Periodic penalty payments are imposed in relation to on-going breaches and therefore are calculated on a daily basis. When deciding on the level of periodic penalty payments, the ECB considered the following factors in particular:
the materiality of the breach, as it prevented Crédit Agricole from having an appropriate basis for identifying whether it was, or might be, exposed to material C&E risks in the short, medium and long-term
the duration of the breach
the average daily turnover of Crédit Agricole at the consolidated level
The enforcement measures against Crédit Agricole followed the imposition of periodic penalty payments on ABANCA Corporación Bancaria, S.A. in October 2025. ABANCA Corporación Bancaria had similarly failed to comply with an ECB decision requiring the Spanish bank to appropriately conduct a materiality assessment of C&E risks. See our previous client insight for further details on that case and on periodic penalty payments generally.
It is important to re-iterate that supervisory scrutiny in this area has been increasing. As outlined in our previous update, since 2020 the ECB has taken several steps to ensure EU credit institutions properly identify, assess and manage C&E risks, including:
In 2020, the ECB set supervisory expectations with the publication of the ECB’s guide on climate-related and environmental risks. This set out expectations regarding the management and disclosure of C&E risks.
In 2022, the ECB took further steps in conducting a stress test on climate-related risks and a thematic review of C&E risks.
Following shortcomings identified by the ECB in 2022, the ECB set staggered deadlines for credit institutions to meet all the supervisory expectations in its guide on climate-related and environmental risks.
The ECB’s move to impose periodic penalty payments on Crédit Agricole highlights its ongoing focus on robust compliance and C&E risk management across the banking sector. The action also reinforces that credit institutions must adhere not only to their statutory obligations under EU and national law but also to the supervisory expectations set by the ECB. In particular, credit institutions should pay close attention to any ECB decisions directed to them individually, ensuring that all required compliance measures are implemented in full to avoid similar penalties.
For further information on this topic, please contact Dario Dagostino, Partner, Mark Devane, Partner, Chloe Culleton, Partner, Eoin O’Connor, Partner, Patrick Brandt, Partner, Eimear O’Brien, Partner, Louise Hogan, Partner, Sarah Lee, Senior Knowledge Lawyer, Jill Shaw, ESG and Sustainability Lead or your usual contact.
