Navigating CP10/25: transforming risk management with climate intelligence

CP10/25 signals a turning point for UK financial institutions. With climate risk now central to resilience and compliance, the PRA urges banks and insurers to sharpen their data and strategies. Here's how climate intelligence can lead the way.
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VanessaBalmbra

Vanessa Balmbra is a Business Development Manager at Haskoning with over 25 years of experience in hazard data and flood risk analytics. She specialises in building strategic partnerships and developing channel sales strategies to deliver Twinn’s climate risk data solutions across a range of sectors. A Chartered Geographer (CGeog GIS) and Fellow of the Royal Geographical Society, Vanessa brings a strong technical background, having previously developed flood data and solutions tailored to diverse markets. She leverages this expertise to help clients across industries maximise the value of Twinn’s climate risk datasets in real-world applications.

The release of the PRA's Consultation Paper CP10/25 in April 2025 marks a pivotal moment for UK banks and insurers. The paper sets out the Prudential Regulatory Authority's (PRA) proposals for updated supervisory expectations for banks and insurers, helping them manage the effects of climate change on their businesses while maintaining their provision of financial services.

For financial institutions, the message is clear: climate risk is central to business resilience and regulatory compliance. The PRA has identified persistent shortfalls in how companies manage climate-related financial risks, including insufficient data granularity, particularly regarding the physical locations of mortgaged properties, which limits companies' ability to assess their exposure to climate events.

What CP10/25 means for your organisation

The consultation period closes today (30th July 2025) with implementation expected to follow in early 2026. Companies will then have six months to submit their finalised roadmaps to the PRA. This timeline means organisations need to act now to ensure they're prepared.

The updated expectations are significantly more sophisticated than the original SS3/19, with much greater focus on governance and decision-making based on climate risk assessments and requirements for:

  • Enhanced Data Requirements: More granular, location-specific risk data
  • Improved Scenario Analysis: Forward-looking stress testing with realistic assumptions
  • Better Integration: Climate risk embedded across all business functions
  • Robust Governance: Board-level expertise and accountability

The data challenge: where many firms fall short

Despite increased attention over recent years, the PRA has identified persistent shortfalls in underdeveloped scenario analyses, with many companies applying overly simplistic or generic stress tests which fail to inform real-world business decisions, and many financial institutions still grappling with:

  • Inadequate Geographic Precision: Generic risk assessments that don't account for specific property locations
  • Limited Hazard Coverage: Focusing only on flooding whilst ignoring other significant physical risks
  • Poor Future Projections: Relying on historical data rather than forward-looking climate scenarios
  • Compliance Burdens: Struggling to provide auditable, decision-useful reporting
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Twinn by Haskoning: your partner for regulatory excellence

At Twinn, we understand the challenges financial institutions face in meeting these enhanced regulatory expectations. Our climate risk intelligence solutions have been used by the financial industry for previous regulatory reporting to address the comprehensive data and compliance requirements outlined in CP10/25, with previous success across the UK's leading financial institutions.

Comprehensive Physical Risk Coverage
We provide all climate peril data required for CP10/25 assessment. Twinn's tool for assessing climate change risk gives risk scoring based on over 19 types of hazard datasets, such as floods (coastal, fluvial, and pluvial), wind, tropical storms, heat, drought, wildfires, earthquakes, volcano activity, and hail. It also provides climate risk scores for now and various future scenarios following the Representative Concentration Pathways (RCPs) and Shared Socioeconomic Pathways (SSPs) in accordance with the latest projections from the Intergovernmental Panel on Climate Change (IPCC).

Proven Track Record with UK Financial Institutions
Leading UK insurers and the majority of lenders use Twinn’s data, either licensing from us directly or through our trusted partner network, to support compliance and drive their risk management and pricing activities. Our solution combines high-resolution climate data with advanced modelling and predictive analytics, seamlessly integrating it with their existing systems.

Meeting CP10/25 requirements with confidence

Our unique approach means that future risks can be quantified for any given year or across any required timeframe, enabling organisations to consider each risk based on the exact duration of an investment, mortgage, or insurance policy.

For Lenders:

  • Property-level flood and climate risk assessment for mortgage portfolios
  • Portfolio-wide exposure analysis and concentration risk management
  • Stress testing capabilities aligned with regulatory scenarios

For Insurance Companies:

  • Detailed risk ratings and supplementary information needed to understand and price risk appropriately, avoid adverse claims and manage over-aggregation of risks
  • Enhanced underwriting capabilities for property and general insurance
  • Input data for claims prediction and loss mitigation strategies
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Acting now: your roadmap to compliance

With implementation expected in early 2026, time is of the essence. Companies are strongly encouraged to start preparing as soon as possible.

Immediate Actions:

  1. Gap Analysis: Assess your current climate risk data capabilities against CP10/25 guidance
  2. Data Strategy: Identify critical data needs and quality requirements
  3. Technology Integration: Plan for seamless data integration with existing systems
  4. Governance Framework: Establish board-level oversight and accountability

Get started today

Don't let data limitations hold back your climate risk management strategy. Twinn's Climate Intelligence provides actionable insights on how natural hazards and severe weather affect your organisation's physical properties worldwide, today and in the future.

Our team of climate risk specialists understands both the regulatory landscape and the practical challenges of implementation. We're here to help you transform CP10/25 from a compliance burden into a competitive advantage.

Contact our team today to discuss how Twinn's physical risk datasets can support your reporting requirements and long-term risk management strategy.

Our solutions help financial institutions worldwide understand, quantify, and manage physical climate risks with the precision and reliability that modern regulation demands.

Vanessa Balmbra -  Business Development Manager

VanessaBalmbra

Business Development Manager