What the policies show
- The law excludes far less than most policies. EU climate benchmarks now exclude only four prohibited weapons, and the SFDR's controversial weapons list does not include nuclear weapons.
- Nuclear weapons are where the policies differ most: from outright exclusion (HSBC, SEB funds) to narrower tests tied to the Non-Proliferation Treaty or to authorisation by named governments (Barclays, ING, Danske Bank).
- Public lenders have moved furthest since 2024: NIB now finances weapons and ammunition, the EIB can lend to companies that make them as long as its money does not fund that activity, and UKEF has a £50 billion defence export fund.
- Several policies can change without notice (EIB, Standard Chartered). A facility that ties its exclusions to a lender's policy 'from time to time' inherits that risk.
Side by side
Each row summarises the published document linked below it. Select a name for the summary and the document date.
| Institution | Conventional weapons | Nuclear weapons | Also excluded or limited |
|---|---|---|---|
| The rules: EU and UK | |||
| European CommissionEU rule-maker · EU | No limit: assess case by case | Outside the SFDR definition of controversial weapons | SFDR disclosure of four controversial weapons: anti-personnel mines, cluster munitions, chemical and biological weapons |
| EU climate benchmarksEU rule · EU | Not excluded | Not in the exclusion | Paris-aligned and Climate Transition Benchmarks exclude four prohibited weapons: anti-personnel mines, cluster munitions, chemical and biological weapons |
| Financial Conduct AuthorityUK regulator · UK | No restriction in FCA rules | Not addressed | UK Paris-aligned and Climate Transition Benchmarks must exclude controversial weapons |
| HM Treasury and the Investment AssociationUK government · UK | Compatible with ESG | Not addressed | None stated |
| Public lenders and export credit | |||
| European Investment BankEU development bank · EU | Will not finance weapons and ammunition; the borrower may make them | Not stated separately | Outside the EU: military or police equipment and infrastructure |
| EIB Group (EIF) defence fundsEU fund investor · EU | Up to a third of a fund, EU and EFTA companies only | Not stated separately | At least two-thirds of a fund in businesses with no weapons and ammunition activity |
| Nordic Investment BankNordic-Baltic development bank · Nordics and Baltics | Permitted, including weapons and ammunition | Not stated separately | Producers of controversial weapons |
| UK Export FinanceUK export credit agency · UK | Supports UK defence exports | Not stated | None stated |
| National Wealth FundUK public investor · UK | Dual-use within its priority sectors | Not stated | None stated |
| Banks | |||
| BarclaysBank · UK | Case by case, with enhanced due diligence | Direct finance only if authorised by the US, UK or French government | Cluster munitions, chemical and biological weapons, anti-personnel mines, equipment for repression or torture |
| HSBCBank · UK | Restricted: no finance or advice for clients that make, trade, buy or sell weapons for military use | Excluded | Also lists lethal autonomous weapons, depleted uranium, white phosphorus, radiological weapons and the treaty-banned weapons |
| Standard CharteredBank · UK | Enhanced due diligence for higher-risk clients | Goods banned by or used for purposes banned by the Nuclear Non-Proliferation Treaty | Goods banned by the Ottawa, Biological and Chemical Weapons, Oslo and Certain Conventional Weapons conventions and the UN Convention Against Torture |
| INGBank · Netherlands | Supports defence funding aimed at Europe's resilience | Does not finance nuclear weapons; may finance non-nuclear activities of companies in NPT countries | Cluster munitions, anti-personnel mines, biological and chemical weapons, depleted uranium and white phosphorus munitions |
| Danske BankBank · Denmark | Finances and invests in the defence industry | Excludes nuclear weapons outside the Non-Proliferation Treaty | Weapons illegal under international law, such as anti-personnel mines, cluster munitions, biological and chemical weapons |
| Investors | |||
| Norges Bank Investment ManagementSovereign wealth fund · Norway | Not excluded | Earlier exclusions for production of nuclear weapons remain | No new exclusions while interim guidelines apply |
| SEB Asset ManagementFund manager · Sweden | Selected funds may invest | Excluded | Prohibited or controversial weapons (cluster bombs, landmines, white phosphorus, chemical or biological weapons) and more than a limited share of revenue from civilian weapons |
The rules: EU and UK
European Commission
Commission Notice C/2025/4950 on the sustainable finance framework, the CSDDD and the defence sector · 30 Dec 2025 (published in the Official Journal) · checked 28 Oct 2026
The Commission says EU sustainable finance law sets no limits on financing any sector, including defence. It wants defence deals assessed case by case, and says excluding defence as a whole, or by revenue thresholds, would not be consistent with the framework. Only four controversial weapons are singled out, for disclosure.
For subscribers: 6 quotes from the document and 3 points on what it means for a deal.
EU climate benchmarks
Commission Delegated Regulation (EU) 2025/1775 on the definition of prohibited weapons · 28 Aug 2025 (adopted; published 30 December 2025) · checked 28 Oct 2026
EU Paris-aligned and Climate Transition Benchmarks used to exclude any company involved in 'controversial weapons', a term the Commission says caused confusion. The regulation replaces it with 'prohibited weapons', limited to four types banned by conventions most Member States have joined. It applies to existing benchmarks from 30 June 2026.
For subscribers: 3 quotes from the document and 2 points on what it means for a deal.
Financial Conduct Authority
Our position on sustainability regulations and UK defence · 11 Mar 2025 (first published) · checked 28 Oct 2026
The FCA says nothing in its rules, including its sustainability rules, prevents investment in or finance for defence companies, and that its rules do not require firms to treat defence differently. Whether to lend is a matter for each lender's own policy. The one exclusion it names is controversial weapons in UK climate benchmarks.
For subscribers: 6 quotes from the document and 2 points on what it means for a deal.
HM Treasury and the Investment Association
Agreed joint statement from HM Treasury and the Investment Association · 23 Apr 2024 · checked 28 Oct 2026
The UK government and the trade body for UK fund managers said that investing in well-run defence companies is compatible with ESG considerations, and that Investment Association members had invested £35 billion in UK defence companies.
For subscribers: 2 quotes from the document and 1 point on what it means for a deal.
Public lenders and export credit
European Investment Bank
EIB update on excluded activities (filed with the SEC) · 19 Jun 2025 (approved by the Board) · checked 28 Oct 2026
The EIB will not finance weapons and ammunition, and outside the EU will not finance military or police equipment and infrastructure. It can lend to a company that makes weapons, provided EIB money does not fund that activity. The Board can change the list without notice.
For subscribers: 3 quotes from the document and 3 points on what it means for a deal, with the defence deals on the register.
EIB Group (EIF) defence funds
Implementation of the EIB Group excluded activities list for intermediated equity investments · 8 Apr 2026 (approved by the EIF and EIB Boards) · checked 28 Oct 2026
For security and defence funds backed by the EIF, at least two-thirds of invested capital must go to businesses with no weapons and ammunition activity. Up to a third may go to EU or EFTA businesses that may be involved in weapons. At least two-thirds must be in EU businesses.
For subscribers: 3 quotes from the document and 2 points on what it means for a deal.
Nordic Investment Bank
NIB's revised Sustainability Policy allows increased defence financing · 12 Jul 2025 (in effect) · checked 28 Oct 2026
Since 12 July 2025 the NIB exclusion list allows it to finance conventional weapons and ammunition, while excluding producers of controversial weapons. It follows a request by the Nordic and Baltic owner governments.
For subscribers: 1 quote from the document and 1 point on what it means for a deal, with the defence deals on the register.
UK Export Finance
UKEF launches £50 billion defence export fund · 30 Jun 2026 · checked 28 Oct 2026
UKEF has a £50 billion Defence Export Fund on top of its £80 billion limit. It guarantees bank loans for UK defence exporters fulfilling contracts and finances overseas governments buying UK defence products.
For subscribers: 2 quotes from the document and 2 points on what it means for a deal, with the defence deals on the register.
National Wealth Fund
Statement of Strategic Priorities to the National Wealth Fund · 19 Mar 2025 · checked 28 Oct 2026
The Chancellor's steer tells the National Wealth Fund to consider dual-use technologies and supply chain resilience within its priority sectors (clean energy, digital and technologies, advanced manufacturing and transport) to support UK defence and security.
For subscribers: 1 quote from the document and 1 point on what it means for a deal.
Banks
Barclays
Defence and Security Statement · Dec 2025 · checked 28 Oct 2026
Barclays provides services to defence companies, including NATO suppliers, and assesses each proposal case by case with enhanced due diligence. It will not serve companies known to make or trade cluster munitions, chemical or biological weapons or landmines, and directly finances nuclear weapons only where the US, UK or French government has authorised it.
For subscribers: 5 quotes from the document and 2 points on what it means for a deal.
HSBC
Defence Equipment Policy Statement · 15 Dec 2022 (date in the file name) · checked 28 Oct 2026
HSBC's published policy restricts the defence sector: it does not provide finance or advisory services to clients that manufacture, trade, buy or sell weapons for military use, which it defines to include conventional weapons. It looks at the whole group, proportionately, and screens dual-use applications.
For subscribers: 5 quotes from the document and 2 points on what it means for a deal.
Standard Chartered
Defence Position Statement · May 2026 (effective) · checked 28 Oct 2026
Standard Chartered will not knowingly provide financial services that support a client making, buying, selling or using 'Prohibited Goods', defined by seven treaties, and runs enhanced due diligence on higher-risk defence clients. It can change the statement without notice.
For subscribers: 3 quotes from the document and 1 point on what it means for a deal.
ING
Our stance: defence · Undated (undated web page) · checked 28 Oct 2026
ING says it supports the defence industry's funding needs where they support Europe's resilience, does not fund controversial weapons, and screens defence companies. For companies involved in nuclear deterrence it finances only non-nuclear activities, and only where the company is headquartered in a country that has signed the Non-Proliferation Treaty.
For subscribers: 3 quotes from the document and 2 points on what it means for a deal.
Danske Bank
We support the increased focus on the defence industry · Mar 2024 (policy adjusted) · checked 28 Oct 2026
Danske Bank works with most of the major Nordic defence companies and adjusted its defence policy in March 2024. It will not do business with a company verified to be involved, directly or through bespoke components, systems or services, in weapons illegal under international law, including nuclear weapons outside the NPT.
For subscribers: 2 quotes from the document and 1 point on what it means for a deal.
Investors
Norges Bank Investment Management
Observation and exclusion of companies · 11 Aug 2026 (list last updated) · checked 28 Oct 2026
Norway's fund is under interim ethical guidelines while a government committee reviews its ethical framework; the committee was due to report by 15 October 2026. Under the interim guidelines Norges Bank makes no new exclusions but may revoke earlier ones. Past exclusions for production of nuclear weapons stay on the list.
For subscribers: 2 quotes from the document and 1 point on what it means for a deal.
SEB Asset Management
More SEB funds open to invest in the defence sector from June 2025 · Jun 2025 · checked 28 Oct 2026
Since 2022 selected SEB equity and corporate bond funds may invest in the conventional defence industry, and more funds joined in 2025. They still exclude nuclear weapons, prohibited or controversial weapons and companies with more than a limited share of revenue from civilian weapons.
For subscribers: 2 quotes from the document and 1 point on what it means for a deal.
Guide: ESG exclusions and defence lending
The rest of this tool covers the wording of each policy, quoted from the published document, what each one asks of a borrower, defence deals on the register for the public lenders, and the drafting points for the facility agreement. It is free with a work email along with the full guides.
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General information on public documents and law as at 28 Oct 2026, not legal advice on any transaction. Filed wording is quoted from the public document linked to it.