FINZ - new(?) rule preventing subsidiaries from submitting targets

Hi, I am advising a UK bank which is 100% owned by a European parent. The UK bank has been developing targets for validation by the SBTi, its parent does not currently have plans to do so. Under the previous corporate net zero standard, subsidiaries were allowed to submit targets for validation. Reading criteria FINZ-C1 of the new FINZ consultation draft, I’m led to understand that it will no longer be possible for FI subsidiaries to have targets validated, this can only be done at the group / parent level. “Financial Institutions should submit targets only at the parent or group level, not the subsidiary level.”.
Please could you confirm that this is indeed the intention of the draft FINZ standard and, therefore, if this means that the UK subsidiary bank will not be able to have its targets validated when the new standard comes out?
Many thanks.

Hello EERW,

The FINZ Standard is still being drafted and the proposed language was intended to solicit feedback from stakeholders. I can not confirm that this will be the final policy for FINZ, but can comment to say that while recommended to submit at the parent level, including all subsidies, it is entirely acceptable to submit targets at the subsidy level under current financial institutions guidance.