Analysing the quality of coal policies

The good, the bad and the in-between of the coal policies adopted by financial institutions

of the financial institutions assessed have adopted a coal policy.

financial institutions assessed have already adopted commitments to stop financing coal developers.

of financial institutions assessed have not committed to exit thermal coal by 2030 in Europe/OECD and 2040 worldwide.

of the coal sector policies adopted in 2023 included commitments to limit financial support to the metallurgical coal industry.

Why track coal policies?

Science is clear. It is imperative to phase out of the coal sector in order to keep the 1.5°C within reach and avoid a climate breakdown. Banks, insurers and investors are increasingly adopting decarbonization targets for the coal mining or power sector.

Yet, these targets are on their own insufficient to achieve 1.5°C-aligned decarbonization. Financial institutions must adopt robust coal sector policies that end all financial services to the expansion of the coal industry while supporting its phase-out.

The Coal Policy Tracker is designed to track the commitments taken by top financial institutions worldwide, highlight the good practices, and shed light on the existing loopholes to be avoided.

The Coal Policy Tracker’s primary objective is simple: to ensure the financial sector is adopting effective coal policies to forcefully contribute to the 1.5°C climate goal. It also enables customers, media, financial institutions and other stakeholders to easily navigate the coal policy jungle.

Coal sector policies alone will not be sufficient to keep the 1.5°C within reach. Broader fossil fuel policies including oil and gas, along with robust sustainable commitments need to be taken by global financial institutions. Their assessments are available on the Oil and Gas Policy Tracker and the Sustainable Power Policy Tracker.

Use the tracker

505 financial institutions are assessed in the Coal Policy Tracker. Last policy update: November 2023.

This financial institution has one of the best practices in the sector.

This financial institution has informed Reclaim Finance that it is working on a new policy which is expected to be published soon.

NA The criterion does not apply to this type of financial institution.

Reclaim Finance could not give a definite score and have contacted the financial institution for clarification.

How to read the results?

Projects

The first criterion covers the exclusion of thermal coal mines, coal plants and coal infrastructure.

See details

Grade	Thermal coal projects
0	No exclusion of thermal coal mines and/or coal plants.
1	Very weak exclusion of new thermal coal mines and/or new coal plants (e.g., vague wording, large/geographical exceptions, etc.).
2	Exclusion of all new thermal coal mines.
3	Exclusion of all new coal plants but large exception.
4	Exclusion of all new thermal coal mines with no exceptions + very minimal exclusion of coal plants. OR Exclusion of all new coal plants with some exceptions.
5	Exclusion of all new coal plants with no exceptions.
6	Exclusion of all new thermal coal mines and plants but potential large exceptions.
7	Exclusion of all new thermal coal mines and plants but potential minimal exceptions.
8	Exclusion of all new thermal coal mines and plants with Carbon Capture and Storage exception.
9	Full exclusion of new thermal coal mines, plants (also excluding existing project retrofits extending the life of the plant).
10	Banks: Full exclusion of all thermal coal mines, plants (also excluding existing project retrofits extending the life of the plant) and infrastructure.	Re/insurers: Full exclusion of all new thermal coal mines, plants (also excluding existing project retrofits extending the life of the plant) and infrastructure.

Penalties
Penalty -1 when the exclusion does not apply to captive projets (e.g., coal plants used for steel, aluminum or nickel production, etc., and not connected to the electrical grid)
[For banks] Penalty -1 when the policy does not cover all financial services dedicated to a specific project.

Penalties do not apply below score 1.

[Re/Insurers] For project-level exclusion, Reclaim Finance considers the following:

Engineering Lines (Construction All Risk – CAR, Erection All Risks EAR)

Expansion

The second criterion addresses the exclusion of all financial services to companies planning new thermal coal mines, coal plants or coal infrastructure projects.

See details

Grade	Thermal coal developers
0	No exclusion of companies because of coal development plans.
1	Immediate exclusion only for new clients with coal expansion plans, or (for re/insurers) when it only applies to new risks, or any other EXPLICIT exclusion of companies with coal expansion plans that will only apply from a date between 2027 and 2030 inclusive.
2	Explicit exclusion of companies with mining and/or coal power expansion plans, but the commitment is only effective from beginning 2025 or 2026 inclusive.
3	Weak, but immediate, exclusion of some companies planning or building new coal projects.
4	Exclusion of companies planning or building more than 1000 MW of new coal power capacity.
5	Exclusion of companies planning or building more than 500 MW of new coal power capacity.
6	Exclusion of companies planning or building more than 300MW of new coal power capacity.
7	Exclusion of companies planning or building more than 100MW of new coal power capacity.
8	Exclusion of companies planning or building new thermal coal mines/plants (≥100MW).
9	Exclusion of companies planning or building new thermal coal mines/plants (≥100MW)/infrastructure.
10	Exclusion of companies planning or building new thermal coal mines/plants (≥100MW)/infrastructure, additional exclusion of companies purchasing existing coal assets without clear commitment to close them and companies selling equipment for new coal projects.

	PENALTIES
Scope	Penalty of -1 or -2 when policy not applied to all assets / all financial services.
	[For investors] Penalty of -1 when bonds are not sold or when it only concerns new investments.
	[For re/insurers] Penalty -1 when the policy does not apply to all the lines of business* of/all risks covered by the re/insurer.
	[For insurers] Penalty -2 when, more than a year after coming into effect, contract renewals are still authorized by the policy.
	[For reinsurers] Penalty -1 when the restrictions do not apply to reinsurance treaties.
Companies/Exceptions	Penalty of -2 when the exclusion does not cover financing subsidiaries and/or when financing to the parent company remains possible.
	Penalty of -1 when minimal exceptions, -2 when large exceptions (e.g., geographical exceptions, financing allowed for vaguely-defined companies, etc.).
	Penalty of -1 if green bonds are not excluded.
	Penalty of -1 when the threshold for coal power developers is 300MW (and not 100 MW), applicable only for financial institutions with 8, 9 or 10 as a base score.
	Penalty of -1 when it only applies to utilities and not to companies planning coal captive projects for specific industrial uses (i.e., steel, chemicals, etc.).

Penalties do not apply below score 1.

Absolute coal power expansion plans figures can be identified in the Prorated coal power expansion plans column of the Global Coal Exit List.

*By all lines of business, we refer to:

P&C (Property & Casualty)
Engineering Lines (Construction All Risk – CAR)
Surety bonds

Relative threshold

The third criterion covers the exclusion of companies which are most exposed to the thermal coal sector, based on their share of revenues or electricity production from coal.

See details

Grade	Thermal coal relative thresholds
0	No exclusion of companies because of their relative exposure to coal.
1	Immediate exclusion only of new clients, or (for re/insurers) when it only applies to new risks, OR any other exclusion of mining and/or power companies that will only apply from a date between 2027 and 2030 inclusive, OR any exclusion that applies from 2025 or 2026, but only for mining OR power, regardless of the threshold(s) on coal mining and/or coal power.
2	Immediate exclusion for existing clients but only on coal mining OR on coal power. OR Any commitment for existing clients that is only effective from beginning 2025 or 2026 inclusive, FOR BOTH MINING AND POWER, regardless of the threshold(s) on coal mining and/or coal power.
3	Weak, but immediate, exclusion for clients for both thermal coal mining and coal power companies.
4	Exclusion of companies > 50 % coal share of revenues (CSR) / coal share of power production (CSPP).
5	Exclusion of companies > 40% CSR/CSPP.
6	Exclusion of companies > 30% CSR/CSPP.
7	Exclusion of companies > 25% CSR/CSPP.
8	Exclusion of companies > 20% CSR/CSPP.
9	Exclusion of companies > 15% CSR/CSPP.
10	Exclusion of companies > 10% CSR/CSPP.

	PENALTIES
Scope	Penalty of -1 or -2 when not applied to all assets / all financial services.
	[For investors] Penalty of -1 when bonds are not sold or when policy only applies to new investments.
	[For re/insurers] Penalty -1 when the policy does not apply to all the lines of business* / all risks covered by the re/insurer.
	[For re/insurers] Penalty -2 when, more than a year after coming into effect, contract renewals are still authorized by the policy.
	[For re/insurers] Penalty -1 when the restrictions do not apply to reinsurance treaties.
Companies/Exceptions	Penalty of -1 when minimal exceptions, -2 when large exceptions (e.g., geographical exceptions, financing allowed for vaguely-defined companies, etc.).
	Penalty of -2 when the exclusion does not cover financing subsidiaries and/or when financing to the parent company remains possible.
	Penalty -1 when wrong metric used for coal power from 20%: revenues and capacity instead of power generation.

The scoring grid goes above 10, applying the same logic (5%=11), to acknowledge exclusion thresholds which are more exigent than our 10% demand before the consideration of penalties, but the overall score is capped at 10. Only the 2 point penalty for policies only covering half or less of the assets is strictly applied to scores above 10.

Penalties do not apply below score 1.

[For Re/insurers] By all lines of business, we refer to:

P&C (Property & Casualty)
Engineering Lines (Construction All Risk – CAR)
Surety bonds

Absolute threshold

The fourth criterion covers the exclusion of the largest thermal coal producers and largest coal plant operators.

See details

Grade	Thermal coal absolute thresholds
0	No exclusion of companies because of their absolute exposure to coal.
1	Immediate exclusion only of new clients, or (for re/insurers) when it only applies to new risks, OR any other exclusion of thermal coal mining and/or power companies that will only apply from a date between 2027 and 2030 inclusive, OR any exclusion that applies from 2025/2026, but only for mining OR power, regardless of the threshold(s) on thermal coal mining and/or coal power.
2	Some immediate exclusion for existing clients but only on thermal coal mining OR on coal power OR Any commitment for existing clients that is only effective from beginning 2025 or 2026 inclusive, FOR BOTH MINING AND POWER, regardless of the threshold(s) on thermal coal mining and/or coal power.
3	Weak, but immediate, exclusion for clients for both thermal coal mining and coal power companies.
4	Exclusion of mining companies producing more than 50 Mt coal a year.
5	Exclusion of mining companies producing at least 20 Mt coal a year ; or any lower exclusion threshold for mining companies but no exclusion of power companies.
6	Exclusion of mining companies > 20 Mt and some power companies based on some absolute criteria.
7	Exclusion of mining companies > 20 Mt and power companies > 15 GW*.
8	Exclusion of mining companies > 20 Mt and power companies > 10 GW*.
9	Exclusion of mining companies > 15 Mt and power companies > 5 GW*.
10	Exclusion of mining companies > 10 Mt and power companies > 5 GW*.

	PENALTIES
Scope	Penalty of -1 or -2 when not applied to all assets / all financial services.
	[For investors] Penalty of -1 when bonds are not sold or when policy only applies to new investments.
	[For re/insurers] Penalty -1 when the policy does not apply to all the lines of business** / all risks covered by the re/insurer.
	[For re/insurers] Penalty -2 when, more than a year after coming into effect, contract renewals are still authorized by the policy.
	[For re/insurers] Penalty -1 when the restrictions do not apply to reinsurance treaties.
Companies/Exceptions	Penalty of -1 when minimal exceptions, -2 when large exceptions (e.g., geographical exceptions, financing allowed for vaguely-defined companies, etc.).
Companies/Exceptions	Penalty of -2 when the exclusion does not cover financing subsidiaries and / or when financing to the parent company remains possible.

Penalties do not apply below score 1.

* Expressed in installed coal power capacity.
**By all lines of business, we refer to:

P&C (Property & Casualty)
Engineering Lines (Construction All Risk – CAR)
Surety bonds

Phase-out

The fifth criterion relates to the quality of the thermal coal phase-out strategy.

See details

Grade	Thermal coal phase-out
0	No corporate phase-out commitment or has announced its intention to phase out thermal coal with no deadline for thermal coal mining and/or coal power.
1	Has announced a thermal coal mining OR power phase-out commitment that will only be fully effective after 2030 in Europe/OECD countries, or after 2040 wordwide. OR Vague phase-out commitment.
2	Has announced a thermal coal mining AND power phase-out commitment that will only be fully effective after 2030 in Europe/OECD countries, or after 2040 wordwide. OR Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining OR coal power. OR Has adopted a very restrictive exclusion criteria that implies an almost immediate full thermal coal mining OR coal power phase-out.
3	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining AND coal power.
4	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power, + Immediate exclusion of some coal developers.
5	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power. + Immediate exclusion of all thermal coal mining and power* developers. OR Has adopted a very restrictive exclusion criteria that implies an almost immediate full thermal coal mining and coal power phase-out.
6	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power + Immediate exclusion of all thermal coal mining and power* developers, + Demand of an exit plan.
7	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power. + Immediate exclusion of all thermal coal mining and power* developers, + Immediate commitment to exclude, by early 2024 at the latest, companies with no exit plan.
8	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power. + Immediate exclusion of all thermal coal mining and power* developers, + Immediate commitment to exclude, by early 2024 at the latest, companies with no exit plan aligned on the above deadlines. + Immediate commitment to exclude, by early 2025 at the latest, companies that fail to provide a detailed asset-by-asset exit plan that covers most of the assets.
9	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power + Immediate exclusion of all thermal coal mining and power* developers, + Immediate commitment to exclude to by early 2024 at the latest, companies with no exit plan aligned on the above deadlines, + Immediate commitment to exclude, by early 2025 at latest, companies that fail to provide a detailed asset-by-asset exit plan that covers most of the assets, + The demand is made to close, and not sell, existing coal assets, + Commitment to exclude clients that plan to convert plants to gas and/or biomass. OR Has adopted a total exclusion criteria that implies an immediate full thermal coal mining and coal power phase-out, but no exclusion of all coal mine/plant developers.
10	Has announced a global thermal coal phase-out by 2040 with the intermediary date of 2030 for Europe/OECD for thermal coal mining and coal power. + Immediate exclusion of all thermal coal mining and power* developers, + Immediate commitment to exclude, by early 2024 at the latest, companies with no exit plan aligned on the above deadlines, + Immediate commitment to exclude, by early 2025 at latest, companies that fail to provide a detailed asset-by-asset exit plan that covers most of the assets, + Commitment to exclude clients that plan to convert plants to gas and/or biomass, + At least one of the two following criteria: Exclusion if companies have a plan to sell, and not close, their coal assets, Immediate commitment to exclude, by early 2026 at the latest, companies without a sustainable transition plan for workers, local communities and the environment. OR Has adopted a total exclusion criteria that implies an immediate full thermal coal mining and coal power phase-out, along with an immediate exclusion of all thermal coal mine/plant developers.

PENALTIES / BONUS
Penalty -2 if [for banks] the commitment only covers lending, or [for investors] a small part of the assets owned and/or managed.
Penalty -2 if [for re/insurers] coverage of new projects are still possible.
[For re/insurers] Penalty of -1 if the commitment covers assets and not companies.
Penalty -1 when exceptions are minimal, -2 when exceptions are significant.
Penalty of -1 if the demands (scores 7, 8, 9 and 10) will be effective after the given dates (2024, 2025 and 2026).
Bonus +1 if the final exclusion threshold is below 5%.

Penalties do not apply below score 1.

*The threshold must be 300MW or lower.

Metallurgical Coal

The sixth and seventh criteria cover the exclusion of metallurgical coal projects and of companies with metallurgical coal expansion plans.

See details

Grade	Projects (not applicable to investors)	Expansion
	No policy	No policy
	Weak exclusion of new metallurgical coal mines.	Exclusion of some companies deriving revenues from metallurgical coal.
	Partial exclusion of new metallurgical coal mines.	Weak exclusion of companies with metallurgical coal expansion plans.
	Exclusion of new metallurgical coal mines AND the expansion of existing metallurgical coal mines.	Not immediate exclusion of companies with metallurgical coal expansion plans.
	Exclusion of new metallurgical coal mines AND the expansion of existing metallurgical coal mines + exclusion of metallurgical coal infrastructure.	Exclusion of companies with metallurgical coal expansion plans.