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Through the European Central Bank’s ‘climate and nature plan’, banks that fall under its supervision are being reviewed and subjected to on-site inspections to monitor the progress of their “digital transformations.”

Although no specific details are given on what “digital transformation” goals banks have been set, we can deduce by following the document trail that this equates to the preparation phase of the digital euro, the European Union’s central bank digital currency (“CBDC”).

In January, Christine Lagarde posted a video message on her Twitter account with the caption: “A hotter climate and nature loss are changing our lives. We must understand what this means for the economy to fulfil our mandate. With our climate and nature plan, we are intensifying our efforts to help underpin stability and support the green transition.”

The sound is so low in the video below that even if you turn your sound up to the highest, it is still inaudible. It’s as if she doesn’t want us to hear what she has to say.

In her tweet above, Lagarde attached a link to the European Central Bank’s ‘Climate and nature plan 2024-2025 at a glance’ web page.

After describing why climate change is relevant to the ECB, the page goes on to state what the ECB is doing about it:

In line with our three strategic objectives, our work on climate change is entering a new phase guided by our climate and nature plan 2024-2025. By building on lessons learnt, the plan outlines where we are broadening our efforts and identifies three focus areas for our activities.

Climate and nature plan 2024-2025 at a glance, European Central Bank

ECB’s “Deep Dive”

The introductory paragraph above concludes with a link to a “deep dive” into the ECB’s “climate and nature plan 2024-2025.”

The “deep dive” sounds like a detailed plan and we would expect to see, well, a detailed plan.  Instead, it is a PDF file containing a cover page and five pages of graphics and bullet points.  Don’t believe us?  You can see for yourself HERE.

Without the detail, the summarised points in the “deep dive” are little more than a meaningless word salad.  On the other hand, having a vague meaningless plan would suit an agenda that wants to keep itself largely hidden from public view, and scrutiny, for as long as possible.

Summarising the ECB’s “deep dive,” the 2024-2025 plan builds on and expands the ECB’s work on five areas of its ‘action plan 2021’, ‘climate agenda 2022’ and ‘supervisory priorities for 2024-2026’. 

One of the five areas that the ECB will be building on and expanding jumps out: “Payments, banknotes and market infrastructure.”  In this respect, the ECB’s ‘climate and nature plan 2024-2025’ states that it intends to:

• Consider environmental aspects in the preparatory phase of the design of a digital euro.
• Consider the relevance of environmental risks in the oversight of financial market infrastructures.
• Eco-design of the next euro banknote series and of banknotes with 100% organic cotton by 2027.

We have not paraphrased the three bullet points above; they are exactly as and all that the “deep dive” says.

Earlier in its “deep dive.” the ECB boasted of its achievements so far.  Again, the image below is all that the ECB’s plan says about its achievements as of the end of January.  Note the comment about bank notes that we have circled in red.  The ECB highlights reducing the environmental footprint in two areas: “our own,” meaning the ECB’s “own,” and “banknotes.”

Granted, the 2024-2025 plan builds on and expands on a previously published plan, agenda and priorities and perhaps there is more detail provided in these documents.  So, what do these documents state about the digital euro and bank notes?

There is no mention of the digital euro or banknotes in the ‘action plan 2021’ or its ‘detailed roadmap of climate change-related actions’.   There is also no mention of the digital euro or banknotes in the ‘climate agenda 2022’.

Regarding bank notes, it’s beginning to seem as if the ECB has achieved something it never set out to do.  Perhaps the digital euro and “reducing the environmental footprint of banknotes” fall under the ‘supervisory priorities for 2024-2026’?

ECB’s Supervisory Priorities 2024-2026

The supervisory priorities “are based on the key risks that supervised institutions face in the current macro-financial and geopolitical environment,” the ECB states.  Adding, “They are revisited annually to reflect changes in the risk landscape and progress made on the previous year’s priorities, and can be adjusted at any time if justified by risk developments.”

The ECB directly supervises 112 “significant” banks and many more “less significant institutions.”  You can see a full list of the financial institutions that are supervised by the ECB HERE. We haven’t counted the number of “less significant institutions” but on the first page there are 50 institutions listed and the list is 35 pages long, which means there are in the region of 1,750 “less significant institutions” that also fall under the supervision, or control, of the ECB.

There is no mention of banknotes either in the Single Supervisory Mechanism (“SSM”) ‘supervisory priorities 2024-2026’.  However, the document does speak of a “digital transformation.” 

Banks have been digital for years; apart from transactions in physical cash, all bank transactions are already digital.  So, it would be interesting to know what, exactly, is the “digital transformation.”

ECB’s Digital Transformation of Banks

We were hoping the text of the SSM’s‘supervisory priorities 2024-2026’ would reveal the answer by way of a definition or listing of goals, but alas that was not the case.  We are left, therefore, to try to deduce what the “digital transformation” plan is from what the ECB’s document has to say about it and any other information we can glean from other sources.

Before we delve into the details of the supervisory priorities text, to give the text some context it is worth noting that the ECB has three supervisory priorities for 2024-2026:

• Priority 1: Strengthen resilience to immediate macro-financial and geopolitical shocks.
• Priority 2: Accelerate the effective remediation of shortcomings in governance and the management of climate-related and environmental risks.
• Priority 3: Further progress in digital transformation and building robust operational resilience frameworks.

“Digital transformation” not only has a dedicated priority – Priority 3 – but, as you will see below, it features in Priority 2 as well.  It would be fair to say that for the ECB “digital transformation” is the priority cloaked in “geopolitical shocks” and “climate-related and environmental risks.”

ECB’s Single Supervisory Mechanism Priorities and “Digital Transformation”

The following are extracts from the SSM’s ‘supervisory priorities 2024-2026’.  Bear in mind as you read through this text that for years banks have already been digitalised.

Introduction

As digital transformation has become a priority for many banks seeking to remain competitive, it is essential that they have adequate safeguards in place to limit potential risks stemming from new business practices and technologies. Supervisory investigations have shown that while some banks have already made good progress with their digital transformation, others have not allocated the necessary resources to achieve their goals.

In the context of the SSM supervisory priorities for 2024-2026, supervised institutions will primarily be asked to … make further progress in their digital transformation and building robust operational resilience frameworks (Priority 3).

2.2 Supervisory priorities for 2024-2026

Priority 2: Accelerate the effective remediation of shortcomings in governance and the management of climate-related and environmental risks

Prioritised vulnerability: Deficiencies in management bodies’ functioning and steering capabilities

Strong internal governance arrangements and effective strategic steering are instrumental in assuring the resilience and sustainability of banks’ business models … Effective strategic steering is also needed to adapt banks’ business models to evolving trends, such as digitalisation and an accelerated green transition.

Priority 3: Further progress in digital transformation and building robust operational resilience frameworks

While most supervised institutions are making progress in the digitalisation of their operations and services and services to cope with ever-increasing competitive challenges, they also need to strengthen and, where needed, adjust their operational resilience frameworks to mitigate potential risks.  Achieving operational resilience should contribute to the sustainability of banks’ business models in the medium term and enable them, among other things, to reap the benefits of innovative technologies. However, some banks are falling behind in achieving their goals in this area.

Prioritised vulnerability: Deficiencies in digital transformation strategies

Strategic objective: Banks should develop and execute sound digital transformation plans through adequate arrangements (e.g. business strategy and risk management) …

Supervised institutions have recently reported record-high profitability, largely driven by higher net interest margins … supervised institutions should be able to manage the envisaged increase in operating expenses without jeopardising much-needed investment in digital transformation. Digitalisation is expected to strengthen banks’ competitive positions and make them more resilient to competition stemming from outside the banking sector.

In 2023 ECB Banking Supervision conducted a horizontal assessment and a benchmarking analysis based on the SSM-wide data collection on digital transformation and the use of financial technology (fintech) … Deficiencies in budgeting and financial planning were [ ] revealed, as banks struggle to monitor the financial impact of their digital transformation initiatives … Going forward, ECB Banking Supervision will continue to focus on digital transformation, combining targeted reviews with dedicated OSIs [on-site inspections]. ECB Banking Supervision will publish its supervisory expectations on banks’ digital transformation.

Main activities as part of the supervisory priorities work programme

Targeted reviews focusing on the impact of banks’ digital transformation on their business model/strategy, governance and risk identification/management, complemented by JSTs’ [Joint Supervisory Teams’] follow-up with banks where material deficiencies are identified.

Targeted OSIs on digital transformation, combining the business model dimension with the IT aspect of banks’ digital transformation strategies.

Publication of supervisory expectations and sharing of best practices on digital transformation strategies.

SSM supervisory priorities 2024-2026, European Central Bank

Let’s sum up the supervisory priorities as they relate to “digital transformation.” The ECB and banks are prioritising digital transformation which will require what seems to be a significant investment.  Because the banks are making record-high profits from interest rates that benefit them, these profits should fund be able to their “digital transformation.”  Additionally, digitalisation should help banks ward off competition.

But we are still none the wiser about what “digital transformation” banks are undertaking or what goals the ECB has set.  So, we need to look at other information published by the ECB to see if it holds any clues.

Technologies for “Digital Transformation”

As we noted earlier in our article, the ECB’s ‘climate and nature plan 2024-2025’ builds on and expands its work on five areas of its ‘action plan 2021’, ‘climate agenda 2022’ and ‘supervisory priorities for 2024-2026’. 

One of the five areas that the ECB will be building on and expanding is “Payments, banknotes and market infrastructure.”  One of the three points noted in this area is to “consider environmental aspects in the preparatory phase of the design of a digital euro.”

Both the ‘action plan 2021’ and the ‘climate agenda 2022’ did not include the digital euro or make any mention of anything digital.  So, if the ECB is being honest about building on and expanding on one of the previous documents, it has to be the ‘supervisory priorities for 2024-2026’.

However, after reviewing the text of the ‘supervisory priorities for 2024-2026’, we still cannot be sure whether the “digital transformation” is what the ECB is building on and expanding to a digital euro.  So, perhaps the technologies that banks are employing for their “digital transformation” hold some clues.

In February 2023 the ECB published an overview of the main takeaways from a survey conducted in 2022 on digital transformation and the use of fintech.  The overview defines “digital transformation” as “a bundle of business model, processes and cultural transformation, enabled by technologies.”

The ECB’s overview of the 2022 survey summarises the technologies that enable banks’ “digital transformation” in the image below.

The two technologies of interest as far as Europe’s CBDC – the digital euro – is concerned are AI and DLT.  But all three technologies noted in the image above point to the term “digital transformation” equating to the digital euro.

Although a decision has not yet been taken on which technology to use, the ECB is experimenting with different technologies, including DLT, in the development of a digital euro. (See Q.23  ‘FAQ on a digital euro’ HERE,)

The ECB is also exploring the relationship of the digital euro with artificial intelligence (“AI”).  Additionally, the digital euro would likely rely on cloud infrastructure for its operation. 

To support the digital transformation of its economy, the European Union has been promoting the development of cloud computing and cloud services. The European Cloud Initiative was launched in 2018 and aimed to create a pan-European cloud infrastructure. The Initiative has since expanded to become the cloud, edge and Internet of Things (“IoT”) initiative and the European Commission is gradually shifting cloud data and services to the edge as part of its digital strategy.

Edge computing is a distributed computing model that brings computation and data storage closer to the sources of data – such as IoT devices – so that a user of a cloud application is likely to be physically closer to a server than if all servers were in one place. This is meant to make applications faster.

The cloud could play a crucial role in the development of a digital euro and it just so happens that cloud computing is widely used across banks (see image above).

With banks using cloud computing, AI and DLT, it would appear that the “digital transformation” is the “preparatory phase of the design of a digital euro” the ECB refers to in its ‘climate and nature plan 2024-2025’. 

This may be why it is stated that in 2024-2025 ECB will “consider environmental aspects in the preparatory phase of the design of a digital euro.”  It did not state it will consider the design of the digital euro itself, because the digital euro is already being designed in the “digital transformation” of banks under the ECB’s supervision.  In short, the “digital transformation” of banks is the “digital euro transformation” of banks.

As Euro News wrote in February: “It is time to be concerned.”  Because the convergence of these technologies means that the digital euro can serve as the arbiter of all exchanges within and with the EU. AI will play a crucial role by analysing financial data and affecting the financial activities of EU residents, citizens, companies and trading partners.

“The digital euro [ ] paired with the emergence of AI, means it is now highly likely that the democratic protections afforded to us in our current system of exchange can be undemocratically replaced by the ability of the state to view and restrict our financial activities,” Euro News wrote. “We deserve better than the digital euro.”