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4. Assessment of EKN and SEK’s alignment with the Paris Agreement

We assess the ‘Paris alignment’ of EKN and SEK based on a methodology specifically developed to evaluate the alignment of ECAs with the Paris Agreement (Shishlov et al., 2021b). This methodology conceptually and practically builds on existing approaches to ‘Paris alignment’ developed for other financial institutions, such as multilateral development banks (MDBs). Most notably, this includes the structure and rationale of the Public Development Banks’ Climate Tracker Matrix by the environmental think tank E3G, which, in turn, is based on the six building blocks of the Paris Alignment Working Group (PAWG) by major MDBs. The assessment of ECAs like EKN differs notably from these two approaches since it transparently underpins each assessment dimension (hereafter referred to as ‘dimensions’) with specific key questions (3-5 questions per dimension, in total 18 questions) as well as specific benchmarks (four benchmarks per question, in total 72 benchmarks). The four benchmarks correspond to four labels of Paris alignment (Figure 2).
Unaligned
0.00 - 0.50
Some progress
0.51 - 1.50
Paris aligned
1.51 - 2.50
Transformational
2.51 - 3.00
Figure 2: Labels of Paris alignment and corresponding score ranges.
This methodology also notably differs from other approaches to assess the ‘Paris alignment’ of financial institutions since it applies a weighting approach to the assessment dimensions. This permits the emphasis of some dimensions over others as some dimensions are more imminently important to reaching the Paris climate goals (e.g., mitigation is more important than disclosure). The selection of weights reflects a careful consideration of priorities and is based on the expertise of experts from research and civil society organizations (Shishlov et al., 2021b). The final scoring for each question is carried out by evidence-based expert judgement. EKN received an overall assessment score of 2.22/3.00 and SEK of 2.30/3.00 and therefore received the label ‘Paris aligned’. The following presents a justification for the scoring of each question per assessment dimension.

4.1 Dimension 1: Financial and non-financial disclosure and transparency

The first dimension is underpinned by four key questions regarding the transparency of financial and non-financial disclosures of the ECAs. This dimension is a crucial prerequisite to evaluate the Paris alignment of ECAs in subsequent dimensions and to hold governments accountable for supporting businesses abroad against their commitments under international treaties, such as the Paris Agreement. Furthermore, it is especially important since ECAs were found to particularly lack transparency in the past (Shishlov et al., 2020). The methodology weighs this dimension
with a total of 20%, recognizing that transparency, while important, is only a precondition for decarbonization itself.
In this assessment dimension, both ECAs were rated with ‘Paris aligned’ with an assessment dimension sub-score of 1.75/3.00.
Q Nr.
Dimension 1 – key questions
Rating EKN
Rating SEK
1.1
To what extent can the GHG intensity of all activities supported by the ECA be assessed based on publicly available data? (Non-financial disclosure)
Some progress
Paris aligned
1.2
In how far can the share of fossil fuel finance over total portfolio be assessed? (Financial disclosure)
Paris aligned
Paris aligned
1.3
In how far can the share of climate finance over total portfolio be assessed? (Financial disclosure)
Some progress
Some progress
1.4
To what extent does the institution adhere to the Recommendations and Supporting Recommended Disclosures of the Task Force on Climate-related Disclosure (TCFD)?
Transformational
Paris aligned

Q1.1: To what extent can the GHG intensity of all activities supported by the ECA be assessed based on publicly available data? (Non-financial disclosure)

This assessment question was rated as ‘Some progress’ for EKN and ‘Paris aligned’ for SEK. EKN is committed to Sweden’s target of net-zero emissions by 2045 but has not (yet) published its financed (scope 3) emissions as it is still an ongoing project (EKN, 2024b).
Data for 2022 and 2023 might be published still in 2025, as part of its annual TCFD-Reports or the Annual Report, as clarified in exchanges between EKN, SEK and the authors.
 Reporting scope 3 emissions is crucial since they are typically the biggest share of an ECA’s GHG emissions (see further section 4.3). EKN has in place the (fairly vague) short-term target to “[reduce] carbon emissions from business travel every year” (EKN, 2022, p. 10),
CO2 2023 < CO2 2019; CO2 2024 < CO2 2023; CO2 2025 < CO2 2024 (ibid.).
 while other emissions from own operations (scope 1 and 2) have been mapped but no short-to-medium-term targets have been defined. In 2022, EKN scored its alignment with the TCFD recommendations (see further Q1.4) as only ‘partially fulfilled’ for the disclosure of scope 1–3 emissions and related risks (ibid.). It should be stressed positively – but not changing the score – that EKN has been offsetting its carbon emissions related to its business flights voluntarily since 2014 (EKN, n.d.a), as the first ECA that was assessed by the authors (Perspectives Climate Research, n.d.).
In 2023, SEK also reported all its operational emissions for the first time (SEK, 2024a).
For SEK, the assessment question was rated as ‘Paris aligned’ as the ECA has been reporting its scope 1–3 emissions transparently for several years and, most recently, reported its financed GHG emissions (scope 3) for the first time (SEK, 2024a; see further Q3.1). Since 2023, it does not report its scope 1 emissions anymore (sources that are controlled or owned by an organisation) as they have been reported to be zero since 2019 (SEK, 2023c, 2024a).
We recommend that EKN and SEK start/continue transparently reporting all scope 1–3 emissions in line with international standards such as the Greenhouse Gas Protocol and the Partnership for Carbon Accounting Financials (PCAF; see further Q3.1)
Discussions between EKN and PCAF are ongoing as of mid-2024, as clarified in exchanges between EKN, SEK and the authors.
 and set sectoral reduction targets for the short-to-medium-term towards net-zero emissions by 2045 or before. We further recommend that, in the medium term, both ECAs publish estimated future emissions data for both their portfolios and new commitments on their websites, including information on baselines and lifetime GHG emissions of assets, to increase the transparency on the climate impact of their business activities.

Q1.2: In how far can the share of fossil fuel finance over total portfolio be assessed? (Financial disclosure)

This assessment question was rated with ‘Paris aligned’ for both ECAs. Data on the share of fossil fuel finance is available as per the E3F joint transparency reporting (see Q3.2 and Q4.3), of which (almost) all the reported finance can be allocated to EKN.
Clarified in exchanges between EKN, SEK and the authors.
 However, the lack of more granularity of publicly available data in addition to E3F reporting does not allow for higher scores.
In its Annual Report 2022, EKN states that “[exposure] to direct fossil assets constitutes barely a couple of per cent of the portfolio” (EKN, 2023a, p. 28) and in 2023 “[transactions] related to fossil extraction and power generation [represented] a declining share of the portfolio” (EKN, 2024b, p. 28) but no more details are provided, such as on project-level.
EKN, 2024b, p. 28 also reports “transactions for which [GHG] emissions are the main risk area”. The number of transactions has decreased drastically (from 19 in 2019 to 0 in 2023), but this only constitutes a climate-related financial risk for EKN.
 SEK, in turn, provides a comprehensive overview of both ‘fossil fuel assets’ and ‘other fossil fuel related assets’, besides ‘sectors sensitive to transition risk’, based on the Global Industry Classification Standard (GICS), the World Resources Institute and UNEP-FI Portfolio Carbon Initiative on ‘carbon asset class by sector’
Fossil fuel assets, fossil fuel dependent infrastructure, high-carbon assets facing shift to low-carbon technologies, and high-carbon assets without low carbon competitors.
 (see Q3.3).
Overall, we recommend refining and extending the E3F transparency reporting, including downstream fossil fuel value chains, and disclosing granular project-level information on transactions that continue to be within the extensive value chains of fossil fuel-related infrastructure. We further recommend reflecting the E3F reporting modalities in all of EKN and SEK’s reporting. This would allow evidence-based decisions to be made for aligning the ECAs with the Paris Agreement and ensure greater public accountability. Specifically, for EKN, we recommend following SEK’s lead to go beyond E3F reporting modalities and comprehensively report on all sectors exposed to fossil-related transition risks (see for example Censkowsky et al., 2022).

Q1.3: In how far can the share of climate finance over total portfolio be assessed? (Financial disclosure)

This assessment question was rated as ‘Some progress’ for both ECAs, for the same reasons stated in Q1.2 regarding the E3F joint transparency reporting. However, while data is provided on the supported RE activities to the E3F, this alone is not sufficient to assess the share of broader climate finance for both ECAs. Similar to Q1.2 – the lack of more granularity of the publicly available data and of a clear definition of ‘climate finance’ by both ECAs do not allow for a higher rating.
Further, in 2024 SEK reported for the first time on gross exposure of RE finance by source of energy, overall EUR 610 million for solar and hydro projects, both for corporates and governments (SEK, 2024a).
Gas power (EUR 0) and power transmission (EUR 110 million) is also reported (ibid.).
 This alone, however, does not justify a higher score as SEK still does not have a clear in-house definition of climate finance or adhere to international standard(s). The same holds true for EKN which disaggregated the share of its energy sector support only once in its 2022 TCFD Report (EKN, 2022c), but not in its Annual Reports so far.
We recommend reporting climate finance both for new authorisations and total exposure as a broader category that includes finance for RE and related infrastructure but also cross-cutting activities for both mitigation and adaptation (Shishlov and Censkowsky, 2022). Such an approach should be based on sound definitions of all subsectors on exhaustive or near-to exhaustive lists of activities. For instance, an established practice for multilateral development banks (MIGA et al., 2022) and the OECD (2022a) provides guidance when support may be deemed eligible under international climate finance commitments.

Q1.4: To what extent does the institution adhere to the Recommendations and Supporting Recommended Disclosures of the Task Force on Climate-related Financial Disclosure (TCFD)?

This assessment question was rated as ‘Paris aligned’ for SEK and ‘Transformational’ for EKN. EKN has first provided comprehensive TCFD-aligned reporting in its TCFD Pilot Report 2021, a subsequent TCFD Report (EKN, 2021b, 2022c) and plans to publish Annual TCFD Reports.
Clarified in exchanges between EKN, SEK and the authors.
 In its Annual Report 2023, EKN transparently reported green transactions (total number and share of portfolio) according to the EU Taxonomy on Sustainable Finance (EKN, 2024b). SEK reported for the first time on the TCFD recommendations in its Annual and Sustainability Report 2020 (EKN, 2021a), but not comprehensively ever since. Both ECAs even preceded Denmark’s ECA EIFO by some years (EIFO, 2023).
We recommend that from their Annual Reports 2024 onwards, both EKN and SEK report according to the newly developed IFRS S1 and S2 reporting standards of the International Financial Reporting Standards Foundation that integrates all the TCFD recommendations (IFRS, n.d.),
In early 2024, the work of the TCFD has been completed and companies‘ progress on the TCFD recommendations is now tracked under the International Financial Reporting Standards Foundation‘s IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures (IFRS, n.d.). 
 thus increasing the degree of detail of the reported information and data. We further recommend that EKN and SEK also start adhering to the Task Force on Nature-related Financial Disclosure (TNFD) whose recommendations promise a more holistic approach to disclosures on environmental risks and opportunities. SEK should also follow EKN’s lead and report the number and share of green transactions according to the EU Taxonomy annually.

4.2 Dimension 2: Ambition of fossil fuel exclusion or restriction policies

The second assessment dimension is underpinned by three key questions covering the ambition of fossil fuel exclusions and/or restriction policies by type of fossil fuel. Today, the most notable policies emerged from the signatories of the Statement on International Public Support for the Clean Energy Transition and members of the E3F coalition. However, the majority of G20 governments only vaguely committed to climate- and or sustainability-related targets, that have substantive interpretative leeway. Due to the pre-eminent importance of rapid phase out of public support for fossil fuel value chains, the methodology weighs this assessment dimension with 40%.
In this assessment dimension, EKN and SEK were both rated as ‘Transformational’ with an assessment dimension sub-score of 3.00/3.00.
Q Nr.
Dimension 3 – key questions
Rating EKN
Rating SEK
2.1
Coal: How ambitious is the ECA regarding exclusions or restrictions for support of coal and related value chains?
Transformational
Transformational
2.2
Oil: How ambitious is the ECA regarding exclusions or restrictions for support of oil and related value chains?
Transformational
Transformational
2.3
Natural gas: How ambitious is the ECA regarding exclusions or restrictions for support of gas and related value chains?
Transformational
Transformational

Q2.1: How ambitious is the ECA regarding exclusions or restrictions for support of coal and related value chains?

This assessment question was rated as ‘Transformational’ for both ECAs. As a member of the E3F, Sweden communicated in November 2022 its National Approaches on the implementation of the COP26 Statement on the Clean Energy Transition Partnership (E3F, 2023a). This has been updated: Since 2023, Sweden’s ECAs must no longer support coal-related value chains at all (EKN, 2023c), a policy decision which was preceded by an agreement of the Participants to the OECD Arrangement on Officially Supported Export Credits to end support for unabated coal-fired power plants (OECD, 2021a).
All Nordic countries, except Norway, have existing policies aligned or nearly aligned with the CETP (OCI, 2024a).
 While EKN’s phase-out policy is indeed transformational and provides a role model guide for other ECAs, practical implementation difficulties may still remain. For instance, the end use of exported Swedish trucks is not always known given intermediary foreign importers. It therefore cannot be entirely excluded that some Swedish exports are used in (transporting) coal, yet EKN’s staff is aware of such situations and actively working to avoid them.
Clarified in exchanges between EKN and the authors.

Q2.2: How ambitious is the ECA regarding exclusions or restrictions for support of oil and related value chains?

This assessment question is rated as ‘Transformational’ for both ECAs. The above justification applies (see Q2.1). The Swedish government instructed EKN and SEK to end new finance for O&G production by the end of 2022, which was implemented via EKN’s Sustainability Policy
According to Pusic, 2022, the initially adopted policy did not clearly rule out support for oil exploration and extraction. However, this version is no longer publicly available.
Updated again in mid-2023 to prohibit guarantees for any expansions and new O&G projects (EKN, 2023c).
 and Sustainable Finance Policy (EKN, 2023c; SEK, 2023d). As is shown in greater detail for Q4.3, EKN still approved two oil transactions in 2021 – thus financing longer than Finland (2020) and Denmark (2018) – but has not approved any fossil fuel transactions in 2022 (E3F, 2023b). SEK, in turn, still reports support for corporates in the sector of O&G and consumable fuels (EUR 370 million; SEK, 2024a) for 2023 – roughly 1% of its total portfolio – from previous new support committed up to 2022 (EUR 280 million; SEK, 2023a) – granted before Sweden’s export finance restriction entered into power.
SEK also left open the possibility that it “may finance projects and activities with high GHG emissions where fossil-free alternatives have not yet been developed, such as mines and fossil fuels for industrial use, provided the project is expected to make a positive contribution to the transition over time.” (SEK, 2024a, p. 122)

Q2.3: How ambitious is the ECA regarding exclusions or restrictions for support of gas and related value chains?

This assessment question is rated as ‘Transformational’ for both ECAs. The above justification (see Q2.1 and Q2.2) applies. In the case of EKN, between 2015 and 2020, gas projects received more support than any other energy source (before Sweden’s export finance restriction entered into power), but no new guarantee has been granted since 2021 (E3F, 2023b).

4.3 Dimension 3: Climate impact of and emission reduction targets for all activities

The third assessment dimension is underpinned by three key questions regarding the climate impact and GHG emissions reduction targets for all the ECAs activities. To achieve the objectives of the Paris Agreement, not only is rapid fossil fuel phase out required, but other sectors need to also drastically reduce absolute emissions levels (IEA, 2021). In the absence of comprehensive GHG accounting, the assessment of this dimension is difficult to evaluate – however, where possible, we look at second-best indicators to proxy the emission intensity of the ECAs portfolios (e.g., fossil fuel-related energy sector finance). The dimension is assigned an overall weight of 20%.
In this assessment dimension, EKN and SEK scored ‘Some progress’ with an assessment dimension sub-score of 1.00/3.00 and 1.33/3.00 respectively.
Q Nr.
Dimension 3 – key questions
Rating EKN
Rating SEK
3.1
Can a declining trend in GHG intensity of the total portfolio be observed? (tCO2e/EUR, Scope 1–3 emissions)
Unaligned
Unaligned
3.2
How significant is the fossil fuel financing relative to total energy-related portfolio? (average of new commitments from the last three years where data is available)
Paris aligned
Paris aligned
3.3
To what extent do all emission-relevant sectors have targeted GHG reduction targets and in how far are GHG reduction targets in line with benchmarks of acceptable 1.5 °C pathways?
Some progress
Paris aligned

Q3.1: Can a declining trend in GHG intensity of the total portfolio be observed? (tCO2e/EUR, scope 1–3 emissions)

This assessment question is rated as ‘Unaligned’ for both ECAs. So far, EKN has not published details on the GHG intensity of its total portfolio, even though its Sus­tai­n­abi­li­ty Policy states among others that “EKN’s risk assessment shall consider the operation’s life cycle [GHG] emissions, possible lock-in effects and transition plans in line with the Paris Agreement’s 1.5-degree target.”(EKN, 2023b, p. 5) Neither EKN nor SEK have committed to join PCAF and disclose portfolio-related emissions.
SEK has been reporting its scope 1–3 emissions (excluding financed emissions) for the last five years, and in 2023, for the first time, also reported its financed emissions (15,748 tCO2e), which are more than 30-times higher than the level of previously reported scope 1–3 emissions. Overall, SEK’s operational emissions have quadrupled since 2021, are now higher than pre-pandemic, and thus not in line with SEK’s target of zero operational GHG emissions by 2030 (SEK, 2024a). Despite its higher transparency compared to EKN, no higher score can be given to SEK since a declining overall trend of the total GHG intensity in the total portfolio cannot be observed (only of its green loans, see further Q4.2).
To start with, we recommend that EKN follows SEK’s lead and significantly improves the transparency of its GHG reporting (see Q1.1), including stating explicitly the financed GHG emissions (scope 3) for all significant transactions. Only full disclosure of GHG emissions on project level would be aligned with the best practice-standard of other ECAs (see further Perspectives Climate Research, n.d.), and joining PCAF would be an important next step for both ECAs.
Ten Swedish commercial banks and financial services groups have already joined (PCAF, n.d.).

Q3.2: How significant is the fossil fuel financing relative to total energy-related portfolio? (average of new commitments from the last three years where data is available)

This assessment question is rated as ‘Paris aligned’ for both ECAs. For SEK, no new support has been provided to fossil fuels in recent years. While the sectoral share of gross exposure keeps falling, it is not (yet) zero and therefore the score ‘Transformation’ cannot be given. As Figure 3 shows, EKN
Swedish data reported to the E3F is exclusively from EKN, as clarified in exchanges between EKN, SEK and the authors.
 has supported fossil fuel exports (EUR 0.6 billion since 2015) – six-times as much as Denmark (EUR 0.1 billion) – but only half of Finland’s amount (EUR 1 billion) and 2% of all E3F member’s fossil fuel support (E3F, 2023b). Up to 2018, fossil fuel financing made up most of Swe­den’s energy-related export finance portfolio, but since then this share in its portfolio has shrunk to 22% since hardly any new fossil fuel support has been provided since then. At the same time, more transactions have been conducted for electric infrastructure (2015-2020) and since 2021 (almost) exclusively to RE (see Figure 5 and Q4.3).
Support to Fossil Fuel Energy Sector
Total
Gas
Oil
Coal
Oil & Gas (undefined)
Value Chain
Credit Value
Credit Value
N* of transa.
Credit Value
N* of transa.
Credit Value
N* of transa.
Credit Value
N* of transa.
Upstream
16
0
0
0
0
16
9
0
0
Midstream
265
256
5
9
18
0
0
0
0
Downstream
0
0
0
0
0
0
0
0
0
Power generation
315
315
4
0
0
0
0
0
0
Total
596
571
9
9
18
16
9
0
0
Supported transactions by targeted sectors on an annual basis (MEUR)
Gas
Oil
Coal
O&G
Total
Electric Infra.
Ren. Energy
Total
2022
0
0
0
0
0
0
509
509
2021
0
2
0
0
2
0
1216
1216
2020
0
3
0
0
3
98
2
100
2019
50
3
3
0
55
194
0
194
2018
0
1
9
0
10
10
0
10
2017
225
0
0
0
225
96
0
96
2016
285
0
4
0
289
16
0
16
2015
12
0
0
0
12
0
0
0
Figure 3: EKN’s fossil fuel transactions, 2015-2022
Source: E3F 2023b, p. 13
Both ECAs have not been receiving many applications by the fossil fuel sector in recent years. They also have explored all options they have under the OECD Arrangement on Officially Supported Export Credits and within their mandates to increase support to the energy transition, including on national content requirements, minimum premium rates, fee waivers for green projects
Clarified in exchanges between EKN, SEK and the authors.
 (see further Q4.4), so that no additional recommendations can be made: Only a further decreasing share of fossil fuel finance down to zero in the stock of both ECAs will eventually increase their score to ‘Transformational’.

Q3.3: To what extent do all emission-relevant sectors have targeted GHG reduction targets and in how far are GHG reduction targets in line with benchmarks of acceptable 1.5 °C pathways?

This assessment question is rated as ‘Some Progress’ for EKN and ‘Paris aligned’ for SEK. As highlighted in section 4.2, since 2022 both ECAs strong fossil fuel exclusion policies in place. Together, both ECAs have recently been developing a method for assessing whether the end use of goods aligns with the Paris Agreement (EKN, 2024b). At the time of writing, this method has been piloted for larger transactions (Project A & B categories), requiring exporters to present emissions data, transition plans and climate risk assessments, but no further information has yet been shared.
This methodology would not become a binding policy but only an internal guidance document, and further progress on sectoral targets is only expected once a target-setting protocol for all NZECA members is released (see further Q5.1).
Clarified in exchanges between EKN, SEK and the authors.
 However, this cannot currently be assessed and will not necessarily result in new sectoral targets that are needed for a whole array of emissions-intensive sectors (and assets). Moreover, emissions-intensive sectors may have their very own transition risks, as it was identified by SEK (see Figure 4).
For EKN, no emission-relevant sector targets existed as of the time of writing. Additionally, defence material transactions that require a permit
From the Swedish Inspectorate of Strategic Products government authority.
 are exempt from the environmental review (EKN, n.d.b) which would be in conflict with setting emission reduction targets.
Whereas SEK has the same independent risk screening for defence sector transaction as for other sectors, even though the Swedish agency Inspectorate of Strategic Products performs risk assessment in their review, as clarified in exchanges between EKN, SEK and the authors.
 Consequently, no higher score could be given to EKN. SEK, on the other hand, has set itself the voluntary goal that its entire lending portfolio, i.e. all government-backed lending for Swedish exports, shall achieve net zero emissions by 2045, with the medium-term target of 50% of green loans by 2030 (SEK, 2021). Among others, SEK’s main sustainability strategy is to focus on increasing the proportion of new lending to companies with ambitious and credible plans to reduce their company’s GHG emissions in line with scientifically based climate targets (SEK, 2024a; see further section 4.4).
Other targets include: Activities that are classified as green in accordance with SEK’s framework for sustainable bonds.; the share of green loans in SEK’s lending portfolio shall increase to 50% by 2030; and SEK’s own operations shall be net zero by 2030.
We recommend EKN and SEK to develop and make sectoral targets publicly available as soon as possible, starting with the highest emitting sectors and guided by the best-available climate science to ensure the Paris alignment of all financed sectors, coordinating this effort with NZECA’s own ambition.
For becoming an NZECA member, it is required to publish Paris-aligned portfolio targets, as already done by both ECAs.
 These targets should be published in Annual Reports and sustainability (finance) policies amended to reflect these targets.
Sectors exposed to transition risk and other assets
2023
2022
Gross exposure
Net exposure
Gross exposure
Net exposure
Fossil fuel assets (linked to sectors)
Skr br
%
Skr br
%
Skr bn
%
Skr bn
%
Fossil fuel assets (Carbon Asset Class 1)
3.7
0.9
0.7
0.2
4.0
0.9
0.7
0.2
Other assets that could be exposed to transition risks (Carbon Asset Class 2)
78.1
18.9
42.5
10.3
74.2
16.9
40.9
9.3
Assets in other sectors not classified as exposed to transition risks
331.4
80.2
370.0
89.5
360.0
82.2
396.6
90.5
Sectors sensitive to transition risk, gross exposure
2023
2022
Sectors
Skr br
%
Skr bn
%
Paper & Forest
16.2
3.9
16.0
3.7
Automobile & Flight Industri
Flight Industri including Aerospace & Defense
10.9
2.6
11.5
2.6
Electric utilities & Power Procedures
15.9
3.9
18.9
4.3
Metals & Mining
12.5
3.0
9.0
2.0
Oil & Gas, Exploration & Production
3.7
0.9
4.0
0.9
Construction & Engineering
13.1
3.2
11.4
2.6
Other sectors sensitive to transition risk
9.5
2.3
7.4
1.7
Total
81.8
19.8
78.2
17.8
Other fossil fuel related assets, gross exposure
2023
2022
Fossil fuel related assets not mapped to the GICS codes as above
Skr br
%
Skr bn
%
Natural gas projects & assets
0.0
0.0
0.1
0.0
Oil & petrol assets
0.0
0.0
0.1
0.0
Potential end use fossil fuel
0.1
0.0
0.1
0.0
Figure 4: SEK’s exposure and sectors sensitive to transition risks and other assets
Source: SEK, 2024a, p. 135

4.4 Dimension 4: Climate finance: Positive contribution to the global climate transition

The fourth assessment dimension is underpinned by five key questions regarding EKN’s contribution to a just climate transition and sustainable development. Rapidly ramping up and improving climate finance is crucial to achieve the objectives of the Paris Agreement and contribute to a green and just post-COVID recovery (Averchenkova et al., 2020). This dimension is weighted with 10%.
In this assessment dimension, EKN and SEK were both rated ‘Paris aligned’ with respective assessment dimension sub-scores of 2.00/3.00 and 2.20/3.00.
Q Nr.
Dimension 4 – key questions
Rating EKN
Rating SEK
4.1
What is the reported share of climate finance over total portfolio?
Some progress
Some progress
4.2
How can the quality/appropriateness of climate finance earmarks be assessed?
Paris aligned
Paris aligned
4.3
What is the share of clean energy financing over total energy-related financing? (average of new commitments from the last three years where data is available)
Transformational
Transformational
4.4
To what extent does the pricing structure take into account climate impacts of activities?
Paris aligned
Transformational
4.5
In how far does the institution ensure positive sustainable development contributions of its activities?
Paris aligned
Paris aligned

Q4.1: What is the reported share of climate finance over total portfolio?

This assessment question is scored with ‘Some progress’ for both ECAs, mostly based on the RE finance reported to the E3F (2023b), which we use as a proxy for climate finance in the absence of a clear definition of ‘climate finance’ and absent granular reporting of it (see also Q1.3 and Q4.3). In the case of EKN, of all new commitments in 2023 (EUR 9.6 billion), only 4% went to the power sector, a drop from 15% in 2022 and 21% in 2021 when historically high support was granted to RE projects (see Q4.3). The share of outstanding power sector commitments of EKN’s total exposure remained constant at 12-14% since 2021, i.e. increasing RE support compensated for decreasing shares of fossil fuel exposure in EKN’s total portfolio (EKN, 2022a, 2023a, 2024b).
For SEK, as mentioned in Q1.3, in 2023 the ECA reported for the first time the share of RE finance by source of energy, committing EUR 610 million for solar and hydro projects (SEK, 2024a). This equals roughly 8% of total new commitments in 2023 (EUR 7.3 billion), similar to the total portfolio of energy-related projects of 1.4% for corporate and 10% for government clients (see Table 1), though these shares still include stock of previous fossil fuel support. No higher score could be given to either ECA as they still do not have in clear in-house definitions of climate finance in place or adhere to international standards (see further Shishlov and Censkowsky, 2022).
We recommend that EKN and SEK strengthen their monitoring and reporting modalities so that researchers and the public can duly evaluate progress on ramping up RE and broader climate finance (see Q1.3). We further recommend that the ECAs seize the vast opportunities that greening export finance offers (e.g., Klasen et al., 2021). Ultimately, aligning EKN and SEK with the Paris Agreement means allocating far more resources to climate-related activities, all of which can boost domestic jobs under the right enabling environment.

Q4.2: How can the quality/​appropriateness of climate finance earmarks be assessed?

This assessment question is scored with ‘Paris aligned’ for both ECAS. None of the two ECAs define climate finance in a transparent way, e.g., with activity-specific components (see also Q1.3 and Q4.1), and they do not differentiate between domestic and international climate finance. However, both ECAs classify green transactions in line with the EU Taxonomy which itself must be considered a best practice approach since the taxonomy is far more granular and adaptable than the Rio markers or the MDB Joint Approach (MIGA et al., 2022; Shishlov and Censkowsky, 2022; OECD 2022a).
For its green bonds, EKN also follows the Green Bond Principles of the International Capital Markets Association, as clarified in exchanges between EKN, SEK and the authors. See further https://www.icmagroup.org/sustainable-finance/the-principles-guidelines-and-handbooks/green-bond-principles-gbp/.
 The taxonomy excludes investments in retrofits of existing fossil fuel power plants that could extent their lifetime but allows to classify investments in gas
And nuclear.
 as ‘sustainable’ (European Commission, n.d.b). Preventing such a possible ‘carbon lock-in’ is a key target of EKN and SEK’s new methodology, which can be used for both known and unknown end use and complements the EU Taxonomy.
Together with the (future) requirement of credible transition plans and sectorial decarbonisation pathways, for instance.
In recent years, an increasing number of applications for projects to EKN and SEK have shown alignment with the EU Taxonomy. Taxonomy-alignment has been assessed either on project level (if the use of proceeds is known) or on company level.
Clarified in exchanges between EKN, SEK and the authors.
 Against this background, EKN (2024b) states that 10% of its guarantee portfolio in 2023
Six transactions with a guarantee volume of EUR 130 million (ibid.); 9% in 2022, 7% in 2021 (EKN, 2024b).
 were ‘green transactions’ and aligned with the climate requirements of the EU Taxonomy. SEK, similarly, reports on ‘sustainability classified loans’, categorised through an in-house system of sustainable (not climate) finance earmarking (‘Sustainability Bond Framework’, ‘Green Bond Framework’), accounting for 16% of the total lending portfolio (2022: 12%; SEK, 2024a). However, SEK goes beyond EKN and reports the reduced GHG emissions from green loans, based on the method stated in the International Financial Institution Framework for a Harmonized Approach to Greenhouse Gas Accounting (ibid.). It also set targets concerning lending on green assets (see Q3.3. and Q4.3).
We recommend clearly defining climate finance in the export finance system and providing granular, project-level reporting (see more recommendations in Q1.3). We further recommend the Swedish government to contribute to streamlining efforts towards a common definition of climate finance in the global export finance system. 

Q4.3: What is the share of renewable energy financing over total energy-related financing? (average of new commitments from the last three years where data is available)

This assessment question is rated as ‘Transformational’ for both ECAs since virtually 100%
In 2021, EKN did indeed support new oil projects with EUR 2 million, but also provided EUR 1.2 billion to RE (EKN, 2022a). The share of fossil fuel support in 2021 was thus virtually 0% (0.16%). For SEK, EUR 370 million are reported for ‘Oil, gas and consumable fuels’ in 2023.
 of all energy-related transactions since 2021 have been for RE and related infrastructure (E3F, 2023b; EKN, 2024b; SEK, 2024a), together with the strong evidence that both EKN and SEK have successfully phased out (most) fossil fuel energy financing in their portfolio over the past years (see section 4.2 and Q3.2). EKN has started supporting climate-friendly technologies such as electric trucks and buses, electric mining equipment, transmission infrastructure for offshore wind farms and solar parks, non-fossil fertilizers and (biofuel-run) public transport (EKN, 2023e). SEK, in turn, lists eight similar green project categories in its Sustainability Bond Framework.
RE, green buildings, energy efficiency, clean transportation, waste management, water and wastewater management, sustainable land use/environmental management and climate change adaptation. See further https://www.sek.se/app/uploads/2022/06/Sustainability-bond-framework.pdf.
 Besides Denmark,
Between 2015 and 2022, Denmark always provided more than EUR 1 billion per year for RE and electrical infrastructure, except for 2017 and 2021 (E3F, 2023b).
 no other E3F-ECA has ever granted as much support to RE in a single year as EKN in 2021, and no member saw a bigger rise in RE support year-on-year as EKN did from 2020 to 2021 (E3F, 2023b).
From EUR 2 million for RE (EUR 100 million with electrical infrastructure) to EUR 1.22 billion.
 In 2022 and 2023, however, RE support dropped compared to 2021, due to various big wind projects for which support was provided only for one year (2021).
Clarified in exchanges between EKN, SEK and the authors.
 Thus, EKN has become the 4th biggest financier of RE among E3F members between 2015-2022 (E3F, 2023a).
Denmark 41%, Germany 19%, France 9%, Sweden 7% (EUR 2.14 billion), Italy 7% (EUR 2.03 billion).
Value Chain
Credit value
Number of transactions
Electric infrastructure
414
28
RE
1,726
18
Total
2,141
46
Figure 5: EKN’s RE and related infrastructure financing in EUR million, 2015-2022
Source: E3F, 2023b, p. 13

Q4.4: To what extent does the pricing structure take into account climate impacts of activities?

This assessment question is rated as ‘Paris aligned’ for EKN and ‘Transformational’ for SEK. Since February 2023, EKN offers a climate reward that is based on the climate impact of activities and the compliance with the EU Taxonomy on Sustainable Finance – the 'Green Export Credit Guarantee’.
Inspired by the Dutch ECA Atradius DSB (Morton, 2022; see further Censkowsky et al., 2022a).
 In fact, it offers up to 100% risk cover for exports to projects that comply with the EU taxonomy (both climate mitigation and adaptation) – 5%-points above EKN’s regular guarantees (EKN, 2023b),
Domestically, EKN implemented a similar ‘Green Credit Guarantee’ in September 2021 already (see Q4.4).
 and does not place any limits in terms of deal size for the new project (TXF, 2023). No guarantee has been issued yet, but discussions are ongoing for a handful of projects.
Clarified in exchanges between EKN, SEK and the authors.
 The power sector
Including both fossil fuels and RE.
 as the third-biggest industry supported by EKN since 2021 has been reported on for many years but RE support has not (set) been reported separately, thus not allowing for a higher score (EKN, 2024b).
SEK, in turn, provides ‘sustainable finance loans’ which offers financing to exporters, subcontractors and projects that contribute to reduced climate and environmental impact or more effective use of resources, in line with the EU Taxonomy (SEK, n.d.a). Its sustainability-linked loans go one step further than EKN and are connected to the entire company’s sustainability targets, e.g. on energy-efficiency enhancements or reduced transportation (SEK, n.d.c). SEK reports transparently on them and they are supposed to contribute to SEK’s target of a 50%-share of green loans by 2030 (SEK, 2024a).
We recommend EKN to publish transparently, comprehensively and as soon as possible data on the demand for the Green Export Credit Guarantee, the average and total amount of guarantees/​loans per year as well as on their effectiveness. Increasing transparency is of particular relevance for improving EKN’s Paris alignment since per its mandate, it cannot waive fees for green projects and has to adhere to national content requirements as per the OECD Arrangement on export finance.
Clarified in exchanges between EKN, SEK and the authors.
 We further recommend EKN (supported by SEK) to request the Swedish Government for amending EKN’s mandate to ensure full Paris alignment. This mandate amendment should build on the instructions of the annual letter of appropriation by the Swedish government which in the last few years clearly stated that “EKN shall transition its operations and activities to be in line with the Paris Agreement's 1.5-degree target and not create lock-ins in fossil fuel dependence.”
 

Q4.5: In how far does the institution ensure sustainable development contributions from its activities?

This assessment question is rated as ‘Paris aligned’ for both ECAs. First, the ECAs adhere to the requirements of the OECD’s Common Approaches for Officially Supported Export Credits and Environmental and Social Due Diligence (OECD, 2022b). As part of the OECD’s requirements, EKN and SEK report on all transactions where a credit period of more than two years has been agreed and the contract value amounts to at least EUR 10 million, as well as on pending applications and approved Category A and Category B transactions (ibid.; see section 2; see further EKN, 2024a; SEK, 2024a). Besides the Common Approaches, both ECAs follow other international guidelines.
E.g., the Equator Principles, the UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, UN Global Compact, OECD Recommendation of the Council on Bribery and Officially Supported Export Credits and the OECD Recommendation on Sustainable Lending Practices and Officially Supported Export Credits (EKN, 2023c; SEK, 2024a).
 This includes the Performance Standards of the International Finance Corporation which comprises eight standards covering the project’s capacity, including on Indigenous People (SEK, 2024a; EKN, n.d.c).
The seven other standards are: Risk Management, Labour, Resource Efficiency, Community, Land Resettlement, Biodiversity and Cultural Heritage (SEK, 2024a).
 Both ECAs impose the same terms, conditions and requirements. In 2023, joint efforts were made to clarify the conditions for loans and guarantees (EKN, 2024b).
In the case of EKN, no higher score can be given since, contrarily to SEK, EKN has not yet started using ESG reports of companies as part of its project assessments, conduct comprehensive emission measurement, reporting, nor future goal setting. Finally, EKN has not defined key corporate responsibility themes – in contrast to Finnvera, for example (Schmidt et al., 2024, forthcoming). We do, however, acknowledge that EKN – in contrast to SEK – dedicates a whole webpage to human rights issues. There the ECA makes transparent how it attempts to minimise the risk of negative impact on human rights via its project assessments, with a focus on the operations where the product is to be used (EKN, n.d.c). Looking towards the future, EKN’s mandate has already been extended to secure Sweden’s access to raw materials and rare earth minerals via a dedicated guarantee, which is particularly important for clean energy industries (EKN, 2022b) and points towards synergies with other Swedish key actors. For the ‘H2 Green Steel’ project, for instance, this includes project financing from SEK, green guarantees from EKN and from the Swedish National Debt Office, besides other consortium members (see further Q5.2) Though SEK has a target of a 50% share of green loans in its lending portfolio by 2030 and reports comprehensively on ESG and broader sustainable development contributions in its annual ‘Sustainability Notes’ for many years, it cannot be scored ‘Transformational’. The ECA itself highlights “potentially conflicting targets, as SEK’s mission includes financing strategic business important to the Swedish government, which does not always align with the SDGs.” (SEK, 2024a, p. 134)
We recommend that EKN and SEK transparently align all operations closer with the United Nations’ Sustainable Development Goals (SDGs) for 2030 and the Paris Agreement’s 1.5 °C temperature limit, as already indicated by EKN, including support for defence and other fossil-fuel dependent sectors.
“The next step involves EKN establishing short- and medium-term climate targets, which will guide efforts towards a greater contribution to the climate transition.” (EKN, 2024b, p. 28)
 For SEK, an amendment to its mandate might be needed to align all strategic business important to the Swedish government such as infrastructure with the SDGs.

4.5 Dimension 5: Engagement - Outreach and ‘pro-activeness’ of ECAs and their governments

The fifth assessment dimension is underpinned by three key questions aimed at capturing the engagement and ambition of climate and sustainability policies of the government and its ECAs in international fora as well as with national exporters and banks. This dimension is weighted with 10%.
In this assessment dimension, both ECAs were rated as ‘Transformational’ with assessment dimension sub-scores of 2.67/3.00.
Q Nr.
Dimension 5 – key questions
Rating EKN
Rating SEK
5.1
To what extent does the institution itself or its government actively engage in relevant international fora (e.g., E3F, OECD, the Berne Union, WTO or the World Economic Forum) to liaise with like-minded for ambitious climate policies in the export finance system?
Transformational
Transformational
5.2
To what extent does the institution itself or its government actively engage in relevant national fora with view to implementing ambitious climate policies in the (national) export finance system?
Paris aligned
Paris aligned
5.3
To what extent does the institution or its government actively engage with national companies to transform fossil fuel-related value chains and incentivize low GHG exports?
Transformational
Transformational

Q5.1: To what extent does the institution itself or its government actively engage in relevant international fora (e.g., E3F, OECD, the Berne Union, WTO or the World Economic Forum) to liaise with like-minded for ambitious climate policies in the export finance system?

This assessment question was scored with ‘Transformational’ for both ECAs. Most importantly, in spring 2023 Sweden took over the Presidency of the Council of the European Union, chaired the Council Working Party on Export Credits and prepared the EU’s negotiating mandate in the OECD. The OECD Arrangement negotiations themselves were chaired by Finland and successfully broadened the possibilities of using financing for green and climate-positive projects,
This includes an extended maximum repayment period for climate and environmental loans from 18 to 22 years (but also for most other projects, from 8.5 and 10 years to 15 years); the minimum guarantee payments will be reduced in the lower risk categories and more flexible repayment terms will also be introduced (Finnvera, 2024).
 aided by Nordic cooperation.
Clarified in exchanges between EKN, SEK and the authors.
 In the Nordic region, ECAs closely collaborate by engaging in discussion and sharing information regularly, both at an Annual Meeting and rather technical sub-group discussions (EKN, n.d.c). Sweden is a member of the E3F coalition which recently hosted a two-day workshop on how export finance can support global climate finance goals,
“[Working] to expand the [E3F] transparency report to more accurately capture the E3F contribution to global climate finance goals.” See further https://www.linkedin.com/feed/update/urn:li:activity:7211311670051127296/.
 a signatory to the CETP, a core member of the Beyond Oil and Gas Alliance (BOGA, n.d.)
Co-launched by Denmark. Finland is only a ‘Friend of BOGA’ and Norway is not among the supporters yet (ibid.).
 and a member of the Powering Past Coal Alliance (PPCA, n.d.), leading the phase-out of export finance for fossil fuels (see section 4.2).
See further Government Offices of Sweden, 2024 for an overview of other Swedish climate transition initiatives.
In June 2023, EKN signed a reinsurance agreement with the Export-Import Bank of the United States to provide more comprehensive support by both agencies, particularly for RE (EKN, 2023d).
Only three months after Finnvera (US EXIM, 2023).
 EKN has prioritised climate policies in the export finance system for many years. Since the inception of the Berne Union’s Climate Working Group in 2022, EKN has been a member and has been chairing it since 2023 (Berne Union, n.d.a)
Canada was the previous chair.
 and in June 2024, for example, organised as webinar for all Berne Union members on climate strategy and function in export credit.
 EKN and SEK have participated actively in the last three COPs (Business Sweden, 2021; EKN, 2022a, 2023a, 2024b; SEK, 2023b) and have been founding members of (NZECA, n.d.)
Together with the Danish EIFO, Export Development Canada (EDC) and UK Export Finance (ibid.).
 within which both ECAs are working on a target-setting protocol for all members as well.
As of the time of publication, this could be either on portfolio or sectoral level, as clarified in exchanges between EKN, SEK and the authors.
We recommend that Sweden continues taking ambitious diplomatic action on a global scale to establish stricter rules governing public support for fossil fuels. This will allow avoiding a situation in which Swedish or European-only ECA support for fossil fuels ends, whilst those from other (generally less climate-concerned) countries continue their business-as-usual. We therefore recommend:
  1. Promoting green export finance during Sweden’s 2024 Presidency of the Nordic Council of Ministers (Government Offices of Sweden, 2024);
  2. Strategizing with like-minded OECD Arrangement participants about how to achieve a transformative climate-related policy reform of the Arrangement, most importantly through adopting full exclusions/restrictions for O&G export finance;
  3. Further deepening and publicly reporting on negotiations at the OECD and its international Infrastructure Working Group (IWG), especially with China, Japan and the US;
  4. Deliberating with like-minded countries about forming a new ‘level playing field’ outside the OECD Arrangement and E3F to accelerate progress and typify the design of a Paris-aligned and sustainable international export finance regulation;
  5. Enhancing and publicly reporting on the Swedish position in international climate-related negotiations involving policies in the export finance system;
  6. Enhancing and publicly reporting on progress on climate- and environmental diplomacy between the OECD and non-OECD members of the export finance system, through the IWG with China, the G7 and G12 Heads of ECA meetings as well as through the Berne Union;
  7. Encouraging Norway to join the Berne Union’s Climate Working Group, become a full member of the E3F, as well as of BOGA;
  8. Encouraging Finland to elevate its commitment to BOGA, from being only a ‘Friend’
    ‘Friends‘ of BOGA (n.d.) “[support] a socially just and equitable global transition to align O&G production with the objectives of the Paris Agreement […]”, but are less committed than Associate Members that have to take at least one of five concrete steps to reduce O&G production.
     of it to becoming an Associate, if not Core Member, and encouraging Norway to become at least a ‘Friend’.

Q5.2: To what extent does the institution itself or its government actively engage in relevant national fora with view to implementing ambitious climate policies in the export finance system?

This assessment question was scored with ‘Paris aligned’ for both ECAs. The Government of Sweden successfully implemented strong restrictions for all support to fossil fuels, in line with the CETP (see section 4.2). ‘Team Sweden’ (of which EKN and SEK are members of) publicly promotes Sweden’s climate and sustainability ambitions, most prominently via Energimyndigheten (Swedish Energy Agency)
“[Energimyndigheten] is leading the energy transition into a modern and sustainable, fossil-free welfare society. They support business development that allows commercialisation of energy related innovations and ensure that promising cleantech solutions can be exported.”
 and Vinnova,
“[Vinnova’s] vision is to be an innovative force in a sustainable world. Vinnova helps to build Sweden’s innovation capacity, contributing to sustainable growth.”
 Sweden's Agency for Innovation (Business Sweden, n.d.). As part of its domestic portfolio, SEK recently supported ‘H2 Green Steel‘ (EUR 500 million),
As clarified in an exchange between EKN, SEK and the authors, see further https://www.sek.se/en/case/revolutionary-h2-green-steel-steel-with-minimal-co2-emissions/.
 with EUR 4.2 billion of investments the world’s first large-scale green steel plant. The plant is export-oriented and received a green credit guarantee as well as an export credit cover for EUR 1.2 billion each from the German ECA Euler Hermes (H2 Green Steel, 2024). This project could serve as a lighthouse for other hard-to-decarbonise sectors which EKN and SEK could support more, both in Sweden and internationally. Other examples of engagement in relevant national fora include quarterly meetings of EKN, SEK; Business Sweden and major exporters to discuss climate and sustainability topics, and the International Council of Swedish Industry where EKN and SEK meet major exporters and banks to discuss challenges such as the climate crisis and co-found initiatives such as the Sustainability Impact Accelerator.
As clarified in an exchange between EKN, SEK and the authors, see further https://nir.se/programmes/sustainability-impact-accelerator/.
Lastly, we acknowledge the leading role of Sweden and Nordic cooperation in broadening the possibilities of using financing for green and climate-positive projects (Finnvera, 2024), but no higher score can be given due to the lack of demonstrated achievements by the Swedish government in transforming domestic export sectors, especially since the rollback of climate ambitions since 2023 (Bryant, 2023; Paulsson and Rolander, 2023).
We recommend that EKN, SEK and the Swedish government closely collaborate with other relevant national actors within (and beyond) Team Sweden to align their approaches and work on a common set of climate targets. Both ECAs should also promote mainstreaming the inclusion of export aspects across all of Sweden’s key climate policy documents such as climate policy action plans and continue to encourage the Swedish government to uphold and strengthen climate targets.

Q5.3: To what extent does the institution or its government actively engage with national companies to transform fossil fuel-related value chains and incentivize low GHG exports?

This assessment question was scored with ‘Transformational’ for both ECAs. For both, the above justification and recommendation (see Q5.2) applies. Further, the Fossil Free Sweden initiative by the Swedish Government’s (Fossil Free Sweden, n.d.) to make it the first fossil-free welfare nation in the world is a great example for government-wide engagement with companies, industries, municipalities and regions. Most prominently, this includes a dedicated finance strategy for fossil free competitiveness that explicitly mentions EKN and SEK’s diverse roles in Sweden and abroad.
We recommend EKN and SEK to keep engaging proactively with those exporters that specialise in low-carbon technologies and climate-friendly exports
Nordic Council of Ministers I www.norden.org/publications I pub@norden.org