5. Conclusions and recommendations

In this study we applied a multidimensional methodology to assess the ‘Paris alignment’ of Finnvera, the official ECA of Finland. The study finds that Finnvera is ‘Paris aligned’ with the objectives commonly agreed under the Paris Agreement. This aggregate assessment outcome is based on evidence we found across 18 questions in five dimensions, including Finnvera’s transparency, fossil fuel exclusion and restriction policies, greenhouse gas (GHG) emissions and targets for its portfolio, contribution to climate finance as well as climate-related engagement. Each assessment dimension is underpinned by precise benchmarks of ‘Paris alignment’ that are informed by best practices in the global export finance system, peer-reviewed literature as well as experts that contributed to the methodology development (Shishlov et al., 2021).

Crucially, in 2021 Finland became a signatory to the COP26 Statement on the Clean Energy Transition (CETP, n.d.) that aimed to phase out all international support to fossil fuels by 2022 and which was implemented via an ambitious, best-in-class fossil fuel phase out policy (E3F, 2023a). This has already contributed to a significant shift from 2019 onwards whereby no more support was provided by Finnvera to fossil fuel projects (E3F, 2023b).

Overall, with a score of 2.20/3.00 – similar to Sweden’s ECAs (2.22/3.00 and 2.30/3.00 respectively; Schmidt et al., 2024) –, Finnvera should be considered an ECA leading to create a ‘level-playing field’ in the global export finance system, particularly in the OECD but also within the E3F and the Berne Union’s Climate Working Group, for instance. Finnvera has not scored ‘Transformational’ due to shortcomings regarding financial and non-financial disclosures, the absence of granular reporting on project-level GHG emissions data, a lacking clear definition of climate finance and its earmarks, and potential for more national engagement to decarbonise Finland’s exports. All recommendations for the Finnish government and Finnvera to improve the scores further are summarised per assessment dimension in Table 3 below.

Table 3: Summary of key recommendations per assessment dimension

Key recommendations for aligning Finnvera with the Paris Agreement
Financial and non-financial disclosure and transparency (*Dimension 1*)	Transparently report all scope 1-3 emissions in line with international standards and set sectoral reduction targets in line with the best-available climate science, together with information on lifetime GHG emissions of assets. Publish the GHG calculation methodology and new commitments in English on the website. Differentiate between support to fossil fuels, clean and other energy as part of the reporting. Publish an annual overview of sectors exposed to fossil-related transition risks and other assets. Disclose granular project-level information of transactions within the value chains of fossil fuel-related/-dependent sectors. Define and report climate finance using unambiguous lists of activities following international best practices. Report on the newly developed IFRS S1 and S2 reporting standards that integrate all the TCFD recommendations and consider adhering to the TNFD as well.
Ambition of fossil fuel exclusion or restriction policies (*Dimension 2*)	No recommendations.
Climate impact of and emission reduction targets for all activities (*Dimension 3*)	Improve the transparency of GHG (intensity) reporting in accordance with the best practices of ECAs. Amend the ‘Environmental and social risk management policy for Finnvera’s financing operations‘ with references to GHG emissions, the urgency and target of Paris alignment and reducing GHG intensity. The Finnish government should extend its net-zero target by 2035 to all scope 3 emissions financed by Finnvera. Follow the best-available climate science and ensure the Paris alignment of all financed sectors. Set and reflect sectoral targets in Annual Reports and other key policy documents.
Positive contribution to the global climate transition (*Dimension 4*)	Strengthen monitoring and reporting modalities, while allocating far more resources to climate-related activities to green export finance further and faster. Enhance the granularity of climate-related reporting. Contribute to streamlining efforts towards a common definition of climate finance in the global export finance system. Transparently align all operations closer to the UN SDGs for 2030 and the Paris Agreement’s 1.5 °C temperature limit.
Outreach and ‘pro-activeness’ of the ECA and its governments (*Dimension 5*)	Take ambitious diplomatic action on a global scale to establish stricter rules governing public support for fossil fuels. Collaborate more with relevant national actors to align on approaches and climate targets and promote the inclusion and mainstreaming of export aspects across Finland’s key climate policy documents. Set Paris-aligned climate targets for all of Finnvera's supported sectors and, MEAE together with other relevant ministries, publish a climate policy action plan for export finance. Work more closely with Finnish exporters and engage proactively with those that have the potential for low-carbon and climate-friendly export activities. Engage more (pro-)actively with national companies to phase out all forms of ‘brown’ export finance.