Sustainability Requirements for FinTech Vendors: Meeting Banking Compliance Needs

Whether you are a payments platform, a SaaS risk engine, a credit scoring provider, or an AI-powered onboarding tool, your banking clients now expect clarity on sustainability. Some banks report directly under CSRD; others follow internal frameworks that mirror the ESRS. In both cases, they require value-chain sustainability information from all technology vendors.

FinTech providers are part of a bank’s extended operational footprint. Data centre energy use, cybersecurity governance, responsible AI, business conduct practices, and workforce conditions all feed into how banks disclose risk and impact. Even small software teams now receive questionnaires that look remarkably like VSME or ESRS templates.

Meeting these expectations does not require large teams or expensive consultants. It requires structured information, consistent disclosures, and evidence that sustainability considerations are embedded into your operations.

If your team wants a grounding in how SMEs approach sustainability reporting, the simplified overview in The VSME Basic Module Explained is a useful reference.

1. Why Banks Are Asking FinTech Vendors for Sustainability Data

1.1 CSRD value-chain requirements

Banks need to understand:

• the environmental footprint of their suppliers
• the social and governance practices of companies they rely on
• how operational resilience and sustainability intersect

FinTech vendors form part of that value chain. Even if you are not in CSRD scope, your clients’ disclosures depend on information you provide.

1.2 Heightened scrutiny of outsourced activities

Regulators increasingly look at:

• cloud dependency
• data processing risks
• algorithmic decision-making
• resilience of critical services

Sustainability in this context is not just environmental — it includes governance, conduct, and workforce practices.

1.3 Competition for bank partnerships

Banks prefer vendors that:

• provide transparent environmental metrics
• demonstrate robust cybersecurity and responsible AI
• maintain strong controls over their subcontractors
• show respect for workers in their own value chain

Sustainability signalling has become part of commercial due diligence.

2. What Sustainability Information Banks Expect from FinTech Vendors

The following dataset reflects common themes across CSRD, ESRS, EBA outsourcing guidelines, and bank-specific vendor assessments.

2.1 Data centre and infrastructure energy use

Banks typically request:

• Total electricity consumption for your hosted environment
• Renewable energy share of your cloud or colocation providers
• Carbon intensity estimates (often taken from cloud provider dashboards)
• Whether you follow low-carbon architecture principles (e.g., efficient compute, serverless or autoscaling models)

If your FinTech integrates with banks in multiple jurisdictions, energy and cloud transparency is essential for their risk modelling and climate disclosures. SMEs often start by providing estimated emissions based on provider guidance — a method similar to approaches described in the Emission Factor Selection Guide.

2.2 Governance and cybersecurity practices

Banks rely heavily on governance clarity. They expect:

• Documented roles and responsibilities for security and sustainability oversight
• Cybersecurity policies aligned with ISO 27001, NIST or equivalent
• Evidence of secure development lifecycle (SDLC) practices
• Regular penetration testing, vulnerability management and vendor assessments
• Incident reporting procedures

These governance structures directly influence a bank’s operational risk and business conduct disclosures.

2.3 Responsible AI and algorithmic transparency

If your product uses machine learning or decision-support algorithms, banks will ask about:

• Bias testing and fairness checks
• Explainability approaches
• Human oversight mechanisms
• Data protection safeguards
• Model monitoring and retraining cycles

Responsible AI expectations are growing fast, especially as banks align with the EU AI Act and report under CSRD governance and conduct topics.

2.4 Workforce and value-chain worker practices

This is where FinTech vendors often underestimate expectations. Banks increasingly want to understand:

• Workforce composition and employment conditions
• Outsourcing to contractors or offshore teams
• How you manage worker well-being, equality and safety
• How you assess worker-related risks in your own suppliers

For banks reporting under CSRD, information on value-chain workers is mandatory. A vendor’s lack of visibility here can delay procurement or trigger remediation requests.

2.5 Business conduct

Banks expect clear statements on:

• Anti-corruption measures
• Conflicts of interest
• Whistleblowing channels
• Ethics and responsible marketing policies
• How leadership ensures integrity in product development

If you want a deeper understanding of how business conduct is treated within sustainability reporting, the topic hub on Business Conduct provides helpful framing.

3. A Structured Sustainability Questionnaire for FinTech Vendors

FinTech companies benefit from preparing a standard response set that can be reused across multiple bank clients. Below is a proportionate questionnaire that mirrors common banking expectations.

Section A — General Profile

1. Company description and key services
2. NACE codes relevant to your operations
3. Countries where development or hosting takes place
4. Subcontractors or cloud providers used

Section B — Environmental Information

1. Total annual energy consumption (or cloud provider-issued estimates)
2. Renewable energy percentage across hosting environments
3. Carbon footprint estimates from compute, data transfer, and storage
4. Any environmental certifications (e.g., cloud provider commitments, internal targets)

Section C — Workforce and Value-Chain Workers

1. Total headcount and breakdown (permanent, contract, self-employed)
2. Health and safety approach for remote or hybrid teams
3. Training provided on ethics, security, sustainability
4. Oversight of subcontracted developers, support teams, or offshore partners
5. Policies addressing equality, fair treatment and labour standards

Section D — Cybersecurity and Governance

1. Information security policies and frameworks in place
2. Data protection and privacy governance
3. Record of breaches or significant incidents (if any)
4. Risk management and reporting structures
5. Board or leadership oversight of sustainability and security topics

Section E — Responsible AI (if applicable)

1. Description of algorithms or ML processes
2. Bias testing and model validation procedures
3. Explainability methods
4. Human-in-the-loop controls
5. Third-party audits or assessments

Section F — Business Conduct

1. Code of Conduct availability
2. Anti-bribery and anti-corruption measures
3. Whistleblowing channels
4. Conflict of interest policies
5. Supplier conduct expectations

FinTech teams may find it helpful to review simplified SME disclosures in CSRD for SMEs: The Complete 2025 Guide to better understand how banks interpret sustainability structures.

4. How Banks Use Your Sustainability Information

4.1 Assessing operational and transition risk

Your data helps banks determine:

• Resilience of your infrastructure
• Exposure to climate-related operational interruptions
• Long-term energy efficiency and cloud dependency risk
• Whether your practices align with their ethical and governance expectations

4.2 Supporting CSRD value-chain disclosures

Banks must disclose:

• Material impacts across their value chain
• Worker conditions and protections
• Governance and oversight structures of key suppliers
• Cyber and operational resilience risks

Your responses feed directly into these sections.

4.3 Informing procurement decisions

Banks may use ESG scoring models when selecting vendors. Vendors with clearer sustainability practices are often prioritised for long-term partnerships, especially in regulated functions such as AML, payments, fraud detection or credit analytics.

5. Steps for FinTech Vendors to Improve Sustainability Readiness

Step 1 — Establish a sustainability “starter set”

Create short, practical documents:

• Environmental summary (energy, emissions estimates)
• Security and risk governance overview
• Workforce and value-chain worker policy
• Business conduct and ethics statement

Small teams can complete this in a week with light drafting.

Step 2 — Collect reliable data from cloud and infrastructure partners

Most cloud providers already offer dashboards showing:

• Region-specific energy usage
• Carbon intensity
• Emission factors
• Sustainability commitments

FinTechs simply need to compile these into a clear annual view.

Step 3 — Document responsible AI practices

Even if AI plays a small role today, banks prefer forward-looking assurance. A short responsible AI statement can significantly reduce follow-up queries.

Step 4 — Build supplier oversight practices

This includes:

• Checks for offshore development teams
• Expectations around worker welfare
• Security and conduct requirements for subcontractors

This aligns your organisation with the value-chain workers topic — an increasingly common section in banking questionnaires.

Step 5 — Train staff in governance and conduct

Sustainable governance starts with people understanding expectations. FinTechs can use micro-learning modules covering security, ethics, privacy, and ESG awareness.

Step 6 — Make disclosures easy for banking clients

Prepare a reusable sustainability pack containing:

• Completed ESG questionnaire
• Policy documents
• Metrics summaries
• Responsible AI statement
• Security certifications

This reduces sales cycle friction and supports trust.

Frequently Asked Questions

What sustainability information do banks expect from FinTech vendors?

Banks typically request environmental metrics (especially cloud energy use), workforce and subcontractor information, cybersecurity governance, responsible AI details, and business conduct policies. To understand how SMEs structure environmental and social disclosures, many vendors reference the simplified guide The VSME Basic Module Explained.

How should a FinTech estimate cloud-related emissions?

Most cloud providers publish region-specific carbon intensities and renewable energy shares. FinTech teams can use these figures to estimate compute, storage and data-transfer emissions. The Emission Factor Selection Guide helps determine which data sources and assumptions are reasonable.

Are FinTech vendors required to meet CSRD directly?

Generally, no. But banks reporting under CSRD rely on vendor data for their own value-chain disclosures. This means FinTechs benefit from providing CSRD-aligned information, even if only in simplified form. For background, many teams revisit the overview in CSRD for SMEs: The Complete 2025 Guide.

How do responsible AI expectations fit into sustainability reporting?

Responsible AI connects directly to governance and business conduct — both part of CSRD. Banks want assurance that vendors test for bias, maintain oversight, protect data, and document model risks. Even basic documentation greatly improves procurement readiness.

Key Terms

• Value-Chain Workers: Workers affected by your operations, including contractors and subcontracted teams.
• CSRD: EU sustainability reporting directive influencing bank supplier expectations.
• ESRS: European standards that shape how banks assess sustainability topics.
• Responsible AI: Frameworks ensuring fair, transparent, and accountable use of machine learning.
• Business Conduct: Ethics, integrity, anti-corruption, and governance practices.

Conclusion

FinTech vendors play an essential role in the banking ecosystem, and sustainability expectations now apply across that whole value chain. By preparing clear disclosures on energy use, cybersecurity governance, workforce practices, and responsible AI, your organisation becomes easier for banks to assess — and more competitive in procurement. With a structured approach and consistent documentation, sustainability becomes not a hurdle but a differentiator that strengthens trust with financial institutions.