Assess transition plans to support transition journeys

Submitted through the COP31 Sustainable Transformation Awards · SKD Türkiye (WBCSD Global Network Partner)

ING Türkiye is a commercial bank with more than 1,000 employees, operating as part of an international banking group (ING Group) with a portfolio-level climate approach known as Terra.

A bank's own operational emissions are small next to the emissions of the companies it finances, so the decisive question for a lender is not how green its offices are but how prepared its clients are to operate in a low-carbon economy. That question was, until recently, answered case by case. Relationship teams formed impressions of a client's climate readiness, but there was no standard frame that made those impressions comparable between clients, between sectors or between years.

The gap mattered most in carbon-intensive sectors, where the difference between a company with a credible transition plan and one without it is a difference in long-term credit quality as well as in emissions.

The ESG.X and Client Transition Plan project, started in 2023 and now scaled and institutionalised in Türkiye, was built to close that gap: to measure, monitor and accelerate the transition of corporate clients through a data-driven methodology, and to connect the result to sustainable finance decisions.

The 2023 financial year was taken as the baseline for the project's impact measurement, and the 2024 assessment round now serves as the baseline for the methodology's own year-on-year comparisons.

Location of the initiative: Türkiye — corporate and business banking clients from İstanbul to Gaziantep, within a global programme via ING Group

The methodology assesses a client on four components: emissions reporting, commitments and targets, transition action plans, and governance and strategy. Together these move the assessment beyond a snapshot of current performance towards a judgement about capacity to transition.

Underneath the four components sit five measured areas. Emission transparency and data quality covers whether Scope 1 and Scope 2 emissions are reported, whether Scope 3 emissions are reported and whether the data has been through independent third-party verification. Climate targets and commitments cover the existence of a net zero commitment, short and medium-term reduction targets, long-term targets, and alignment with 1.5°C or with the Paris Agreement. Transition plan and delivery capability covers defined reduction actions, identified transition investments, product and service transition roadmaps and low-carbon business model development. Governance and strategic integration cover the integration of climate into corporate strategy, board or senior management accountability, named teams or committees responsible for the transition plan, and the treatment of climate risk in corporate decision-making. Low-carbon product and service development covers low-carbon offerings, circular economy practices, renewable energy solutions, energy efficiency projects, and electrification and alternative fuel investment.

Two data routes serve two client segments. For corporate banking clients the assessment is built from public disclosure — sustainability reports, annual reports, climate reports and company statements. For business banking clients, where public disclosure is limited, a structured 10-question transition survey is completed with the client directly.

The scoring produces a comparable result per client, expressed on a ten-point scale and grouped into advanced, moderate and low maturity bands. Final scores are confirmed by the relevant relationship teams rather than accepted automatically from the platform.

The output is not a credit decision. The methodology was not designed as a lending allocation mechanism; it has become one of the significant inputs to sustainable finance processes and to the conversation the bank has with each client about transition plans, reduction targets, investment plans and the financial instruments available to fund them.

Figure 1: Chart of the score distribution across the corporate clients assessed on 2024 data, with the cumulative share reaching each score threshold

Sustainability impact

Climate

The initiative is an enabler rather than a direct abatement measure: the emissions it addresses are those of the companies assessed, not those of the bank's own premises or fleet.

The assessment explicitly examines whether each client reports Scope 1 and Scope 2 emissions, whether Scope 3 emissions are reported, and whether the emissions data has been independently verified, so improving emission transparency in the client base is the first measurable effect. Targets are tested against 1.5°C and Paris Agreement alignment, which helps clients move from stated ambition towards science-based commitments.

For the bank itself the exposure concerned is the emissions associated with its lending and investment portfolio rather than its own operations, and the portfolio-level framework aims to align high-emitting sectors with net zero pathways. The methodology and the underlying Scope 1, 2 and 3 emissions calculations follow the guidance of the GHG Protocol and PCAF, with financed emissions reported under Scope 3 Category 15 (Investments).

The results give the first standardised picture of client maturity. Of the 43 corporate clients whose assessment in 2024 financial-year data was completed, 13 achieved the maximum score of 10 out of 10; 6 scored 9 or above; 7 scored 8 or above; 3 scored 7 or above; 1 scored 6 or above; 6 scored 5 or above; 3 scored 4 or above; 1 scored 3 or above; and 3 scored 2 or above. Cumulatively, 44 per cent of clients, or 19 clients, reached 9 points or above, 60 per cent, or 26 clients, reached 8 or above, and 67 per cent, or 29 clients, reached 7 or above.

The 13 clients at the maximum score are prominent Turkish organisations that report greenhouse gas emissions comprehensively, publish their transition strategies, integrate climate targets into corporate governance and carry sustainability investment through into operations.

Social

The methodology widens access to structured transition assessment rather than restricting it to large companies. Extending the work into the business banking segment in 2025 brought smaller firms, which rarely have the resources to prepare public climate disclosure, into a formal assessment for the first time.

Those clients span a wide geography, from İstanbul to Gaziantep, and a wide sector mix: manufacturing 8, metal and metalworking 8, paper 5, automotive 3, textiles 3, energy 2, food 2, chemicals 2, plastics 1, water management 1 and agriculture 1.

The concentration in carbon-intensive sectors — energy, metal, manufacturing, automotive and chemicals — means the assessment reaches the parts of the economy where transition capability is hardest to build and most consequential.

The one-to-one meetings that follow each assessment function as capability transfer: development areas are shared with the client, and awareness of sustainable finance solutions has been observed to increase during the face-to-face discussions in the business banking segment.

Business impact

Benefits

The first benefit is comparability. A client portfolio that had never been subject to a standard climate transition assessment is now analysed under one systematic methodology, so relationship and risk teams can compare clients against each other and against previous years rather than against impressions.

The second is engagement. In 2024, one-to-one meetings were held with 100 per cent of the clients in scope, covering verification of public data, assessment of existing climate targets, review of transition plans, identification of sustainable finance needs and discussion of development areas. That converts a scoring exercise into a client relationship activity with a defined agenda.

The third is pipeline. Transition plans, emission reduction targets, investment plans and sustainable finance instruments are discussed actively in these meetings, and interest in sustainable finance solutions has increased visibly in the business banking segment, which makes the methodology an accelerator of transition investment rather than only a measurement tool.

The fourth is differentiation. In client meetings conducted in the corporate segment, and continuing with small and medium-sized firms, clients reported that other financial institutions were not approaching them with a comparable assessment framework.

Scale supports all four: approximately 1,600 wholesale banking clients have been assessed under the same platform and methodology globally at the ING Group level, and the same number of clients has been engaged in strategic transition conversations globally.

Costs

The dominant cost is analyst effort. Assessing a client from public disclosure means reading sustainability reports, annual reports and climate reports and applying the criteria consistently, and in Türkiye the methodology was first applied to large clients through a spreadsheet-based structure rather than through the global platform, which made the first rounds labour-intensive.

That cost was addressed by automation. In 2025 the process was automated with global coordination, data is analysed through the platform and scores are produced systemically, with final scores confirmed by the relevant teams.

Data availability is the principal dependency and the principal risk, together with client maturity. Where clients do not publish, the assessment cannot be built from public sources at all, which is why the business banking segment required a separate 10-question survey completed with the client — a method that costs relationship time instead of analyst time.

Local adaptation carries its own cost: a methodology developed globally has to be adapted to local market conditions and local disclosure practice by local teams.

There is also a limit on the return. The methodology is not a credit allocation mechanism, so the benefit is indirect and accrues through better-informed lending and stronger client dialogue rather than through a direct pricing rule.

Before the change, the sustainability team manually reviewed and scanned documents such as sustainability reports and integrated annual reports to evaluate each company and fill in the corresponding spreadsheets. Alongside other daily responsibilities, this took up to two days per company. Once a dedicated pool of analysts took over the spreadsheet work, automated systems located the required data through keywords and other identifiers, and the spreadsheets were completed more quickly and more accurately than before. Taking over and automating the task improved the quality of the assessment and reduced the workload on the team. The team now reviews the analysts' output and comments where necessary, which takes at most half an hour per client.

Impact beyond sustainability and business

Co-benefits

The assessment gives clients a structured diagnostic they would otherwise have to buy: a view of where their emission reporting, targets, transition plan and governance stand against a consistent frame.

Because the same methodology is applied across the ING Group operating in many markets, results in Türkiye are comparable with results elsewhere, which allows local performance to be positioned internationally.

Building a client-level baseline in 2024 creates the conditions for measuring transition speed rather than transition status, since re-assessment on the same client universe reveals movement between maturity bands.

Potential side-effects

Assessment from public disclosure rewards disclosure quality as well as transition substance. A company that transitions well but publishes little will score lower than its performance deserves, which is why validation meetings and, for the business banking segment, a direct survey are necessary corrections rather than optional extras.

A standard score can be over-interpreted. The methodology was not designed as a credit allocation mechanism, and treating it as one would attach lending consequences to a measure built for engagement.

Coverage is still partial. Assessment work on 3 clients was carried into a following period because of company-specific circumstances, and in the business banking segment the survey process is still ongoing, so segment-level conclusions should not be drawn from early results.

Year-on-year progress indicators are not yet publishable. Additional analysis of movement between maturity bands is under way at ING Group level, but at the date of assessment no final data set suitable for public disclosure and independent verification had been produced, so only completed and quality-checked results are reported here.

Typical business profile

The model suits banks and other financial institutions with corporate lending portfolios concentrated in carbon-intensive sectors, where portfolio decarbonisation depends on client behaviour rather than on the institution's own operations.

It requires a sustainable finance function able to define and maintain assessment criteria, relationship teams willing to carry the results into client conversations, and a data route — either public disclosure analysis or a structured survey — appropriate to the segment being assessed.

The methodology also transfers beyond banking to any organisation that needs to assess the transition readiness of a large counterparty base, such as insurers, investors or main contractors assessing suppliers, because the four assessment components are not specific to lending.

Approach

1. Fix the assessment frame before scoring anything: Define the components the assessment will cover — emissions reporting, commitments and targets, transition action plans, and governance and strategy — so that every client is judged against the same structure regardless of sector.

2. Turn the frame into testable criteria: Break each component into observable items such as Scope 1 and Scope 2 reporting, third-party verification, net zero commitment, alignment with 1.5°C, defined reduction actions, board-level accountability and low-carbon product development, so that scoring rests on evidence rather than on judgement.

3. Start with the segment that already publishes: Apply the methodology first to corporate clients whose sustainability reports, annual reports and climate reports allow an assessment to be built entirely from public sources, which produces a first full round without depending on client availability.

4. Validate every score with the client directly: Hold one-to-one meetings with the clients in scope to verify public data, assess existing targets, review transition plans, identify sustainable finance needs and share development areas, so that the score is corrected and the assessment becomes a conversation.

5. Automate only once the manual round has proven the method: Move scoring onto a platform after a complete manual cycle has exposed the edge cases, and keep a confirmation step in which the relevant teams approve final scores rather than publishing platform output directly.

6. Design a second route for clients without public data: Build a structured 10-question transition survey to be completed with the client for segments where public disclosure is limited, so that smaller firms are assessed on comparable criteria rather than excluded.

7. Connect the score to the financial conversation: Use the assessment as an input to sustainable finance processes and discuss transition plans, reduction targets, investment plans and financing instruments in the same meeting, without converting the score into an automatic credit rule.

8. Re-run on the same client universe each year: Repeat the assessment annually with the following year's financial data so that movement between maturity bands becomes measurable, and treat the first complete round as the baseline for those comparisons.

Stakeholders involved

• Project leads: The project is run under senior management ownership, in line with ING Group's sustainable finance strategy and the Terra portfolio approach. The methodology and the underlying platform were developed within the global framework, and local teams adapt and apply them to the Turkish market where possible, which keeps comparability within the ING Group while allowing for local disclosure practice. Final scores are confirmed by the relevant teams before they are used, so accountability for the result sits with named functions rather than with the scoring system.

• Company functions: Governance rests on coordination between the sustainable finance teams, the corporate banking teams and the related business units. The sustainable finance teams own the methodology and the criteria; the client-facing teams carry the assessment into practice, run the validation meetings and integrate results into decision-making for discovering sustainable finance product and service provision opportunities. This division is what connects the methodology to financing decisions rather than leaving it as an analytical exercise. The project is aligned with medium and long-term strategic objectives and supported by resource allocation and a continuous improvement approach.

• Main providers: The assessment platform and the transition plan methodology are provided from within the ING Group rather than procured externally, and global coordination supported the automation of the process. International standard-setting bodies and initiatives working on emissions disclosure and science-based targets provide the reference points for the assessment criteria, and reporting frameworks covering greenhouse gas accounting and sustainability disclosure inform how the criteria are defined.

• Other: Corporate clients are the principal external stakeholder and the main feedback channel. One-to-one meetings held after scoring are used to verify data and to develop the methodology, and clients contribute insight about their own transition processes that feeds back into the model. Client teams apply the framework in the field and integrate it into decision processes; international frameworks and initiatives supply the criteria against which emission reporting, targets, action plans and governance are judged. As of 2025 the corporate segment process has been automated and moved onto the global platform, while client meetings continue in the small and medium-sized enterprise segment, where coverage teams fill in the relevant survey together with the client and proceed with continuous dialogue.

Key parameters to consider

The programme began in 2023 and was applied first to corporate banking clients. Assessment in 2024 financial-year data brought 46 clients into scope, of which 43 were completed and 3 were carried into a following period; the submission records 52 corporate clients assessed in Türkiye as of 2025. Re-assessment of the same client universe using 2025 financial-year data is under way.

Extension to the business banking segment began in 2025. As at August 2026, 36 clients were in scope, 14 surveys have been completed and 22 client processes are continuing, with the intention of assessing all clients in scope.

Data availability and client maturity are the two constraints that determine how fast the coverage can grow, and regulatory pressure is the factor most likely to accelerate it.

Globally at ING Group level, approximately 1,600 wholesale banking clients have been assessed under the same methodology as of 2025.

Implementation and operations tips

Running the first cycle manually is worth the effort. The spreadsheet-based round in Türkiye exposed how the criteria behave against real disclosure before the process was automated, and automation applied to an untested methodology tends to industrialise its errors.

The validation meeting is where the value is created, not the score. Meeting 100 per cent of the clients in scope turned an assessment into an engagement programme and produced the corrections that made the scores usable.

Segment-specific data routes are necessary rather than optional. Applying a disclosure-based method to firms that do not publish produces a measurement of transparency, not of transition, which is why the 10-question survey exists.

Keeping the score outside the credit decision protects it. Because the methodology is an input to sustainable finance processes rather than an allocation rule, clients engage with the assessment as a diagnostic rather than defending a number.

Publish only what can be verified. Year-on-year maturity movement is being analysed but has not been released, because no final data set suitable for public disclosure and independent verification existed at the date of assessment.