How PortfolioCheck maps onto the Bank of Ghana Climate-Related Financial Risk Directive, 2024. PortfolioCheck is the Ghana-calibrated physical-climate-risk engine for the mortgage and property collateral book. It operationalises the Directive's own example physical metrics (Table 1) and the physical-risk elements of Paragraphs 48, 43(f), 43(g) and 43(d), and feeds the bank's governance, ICAAP and disclosure processes. It does not — and does not claim to — cover institutional governance or transition risk.
core/directive.py; it updates automatically when the model changes. Clause references are to the
Directive's November-2024 text — the semi-annual return is Para 48; Para 46 is the forthcoming
Standardized Disclosure Template.Part IV-B, Para 48 (a–m) — the filing PortfolioCheck is built to produce
| Clause | Directive requirement | PortfolioCheck |
|---|---|---|
| 48(h) | Physical-risk data on the vulnerability of assets, climate risk drivers and exposures Per-asset flood/coastal/heat/riparian/land/drought scores + exposure at risk; from v2.6.0 the composite re-weights to each asset's materiality profile so its dominant peril leads, transparently and recalibratable per bank. | Core output |
| 48(l) | Exposures subject to physical risks (chronic & acute) split by geographical region/location, and the proportion of total exposures and total assets `by_region` split + High+ share of total exposure; the return's headline table. | Core output |
| 48(m) | Details of the methodology used to determine exposures subject to physical risk `scope_methodology` block states every assumption up front for the supervisor to accept. | Core output |
| 48(f) | Description of risk-assessment methodologies including stress-testing scenarios and assumptions Physical-risk portion: scenario pathway, parameter set, vulnerability/money/scenario basis all disclosed. Whole-RFI stress-testing is the bank's. | Partial |
| 48(b) | Metrics on assets in highly vulnerable sectors and geographical locations The GEOGRAPHICAL-location half is produced; the vulnerable-SECTOR / carbon-intensive half needs the bank's book. | Partial |
| 48(i) | Forward-looking information — scenario-analysis results and forward-looking metrics Physical-risk portion: per-asset IPCC AR6 / NGFS projection. Transition plans + stress-testing results are the bank's. | Partial |
| 48(k) | The process for identifying vulnerable concentrated exposures and assessing likelihood and impact Concentration by region and property type + the acute return-period tail. | Core output |
| 48(j) | Exposure to transition-risk sectors (mining, carbon-intensive) as a proportion of total Transition-risk / sectoral — needs the bank's whole loan book, not a collateral screen. | Needs bank's book |
| 48(a) | Description of material risks and the governance / risk-management / strategy approach The tool supplies the physical-risk evidence; the governance narrative is the bank's. | Needs bank's book |
| 48(c) | Internal policies to reduce the RFI's own carbon footprint The institution's own operational emissions — not a portfolio screen. | Out of scope |
| 48(d,e,g) | Requirements imposed on borrowers; energy-sector transition steps; corporate transition-plan info Transition-plan matters — Part V, outside a physical-risk screen. | Out of scope |
Part IV-A, Para 43(f) — the method a bank must disclose; PortfolioCheck IS that method
| Clause | Directive requirement | PortfolioCheck |
|---|---|---|
| 43(f)(i) | Selected climate-related events (chronic & acute) and the rationale given the business model Six hazards mapped to the Directive's taxonomy — flood and coastal (acute storm-surge / chronic sea-level & erosion), heat, drought, riparian proximity, and land/environmental constraint. Rationale documented; landslide, windstorm and wildfire are scoped out for a mortgage book and named as such (add on request). | Core output |
| 43(f)(ii) | Criteria for the geographical breakdown / granularity used to assess physical risk Asset/object level (coordinates / GhanaPostGPS), aggregated to region — stated per ECB good practice. | Core output |
| 43(f)(iii) | The time horizons and scenarios used to assess physical risks IPCC AR6 SSP1-2.6 / 2-4.5 / 5-8.5 and NGFS pathways spanning the low/intermediate/high envelope, over short (→2030) / medium (→2050) / long-term (→2100) horizons per Para 40(d). | Core output |
| 43(f)(iv) | Considerations for identifying exposure vulnerable to physical risk by geolocation of the counterparty's activity Collateral located per asset; PCAF 1–5 data-quality flag on every geolocation. Where Sentinel-1 SAR observed inundation on the parcel, that observed-flood evidence (with date) is attached to the geolocation. | Core output |
Part IV-A, Para 43(d)(ii) & 43(g); Table 1 (Para 36)
| Clause | Directive requirement | PortfolioCheck |
|---|---|---|
| 43(g) | Identifying, monitoring and reporting concentration of exposures within sectors or geolocations Geographic concentration of High+ exposure + property-type split; acute-tail worst-region loss. | Core output |
| 43(d)(ii) | Exposures subject to physical risk by geographical area and the proportion to total exposures / assets The return's core metric. | Core output |
| Table 1 | Example physical metric — number & value of mortgage loans in 100-year flood zones The Directive's OWN example metric — PortfolioCheck computes exactly this. | Core output |
| Table 1 | Example physical metric — proportion of property in areas subject to flooding, heat stress or water stress Produced directly from the six-hazard screen. | Core output |
| Table 1 | Example — climate opportunities & investment in adaptation measures Surfaces the asset-level adaptation / green-lending PIPELINE that feeds the bank's Table-1 opportunity & capital-deployment metrics; the bank computes its own % revenue invested. Measures are submitted to BoG with evidence as a dated case; nothing is credited until BoG accepts. | Feeds bank process |
| 43(d)(iv) | Exposure to carbon-intensive sectors and counterparties, and renewables, as a proportion of total Transition metric — needs the bank's whole book. | Needs bank's book |
| 43(d)(v) | Exposure to each vulnerable sector per the SBP Sector Guidance Notes, as a % of total exposures The property book maps onto the SBP Construction & Real Estate Sector Guidance Note; the % of total across all vulnerable sectors needs the bank's whole book. | Partial |
Part III — the process the return feeds into
| Clause | Directive requirement | PortfolioCheck |
|---|---|---|
| Para 35(a) | Collect reliable geolocated physical-risk data; use reasonable proxies where data gaps exist Geolocation + a PCAF data-quality flag and an explicit proxy disclosure per asset. | Core output |
| Para 32 | Consider NGFS scenarios, complemented by scenarios reflecting the physical vulnerability of the RFI's geographical locations NGFS pathways mapped to AR6 physical forcing; the Ghana-specific location hazard model IS the Para-32 RFI-specific physical complement the clause mandates. | Core output |
| Para 39–40 | Use scenario analysis to assess resilience to plausible climate pathways over a range of horizons Provides the physical-risk scenario view; the business-model resilience assessment is the bank's. | Feeds bank process |
| Para 37(a) | Incorporate climate credit risk across the entire credit life-cycle, including at client onboarding Point-of-origination API screens a property at application; overlay AAL → repricing → climate ECL. | Feeds bank process |
| Para 31 / 33 | Quantify climate risk for the ICAAP; key risk indicators, heatmaps, risk matrix; disclose methodology, judgement and proxies Supplies the physical-risk figures, heatmap and proxy/PCAF disclosure the ICAAP needs; capital integration is the bank's. | Feeds bank process |
| Para 46 | File in the format of the Standardized Climate-related Disclosure Template (to be issued by BoG with the ICAG) Template not yet published; the return is built to map onto it and is offered to help shape it. | Feeds bank process |
Governance, transition plans and emissions belong to the bank, not a screening tool
| Clause | Directive requirement | PortfolioCheck |
|---|---|---|
| Part III-A | Corporate governance — board oversight, three-lines-of-defence, risk-appetite statement Institutional governance. | Out of scope |
| Para 30 | AML/CFT measures against financing of environmental crimes Compliance function, unrelated to physical-risk screening. | Out of scope |
| Para 37(c,d) | Market-risk and liquidity-risk assessment of climate drivers Beyond collateral/credit — the tool informs the collateral view only. | Out of scope |
| Part V | Credible climate-related transition plans towards net zero Institutional strategy — transition risk, out of a physical-risk screen. | Out of scope |
| Para 42 | Disclosure inside the Audited Financial Statements / IFRS S2 The tool produces the underlying physical-risk figures; the statutory disclosure is the bank's. | Feeds bank process |