The AFM has published that it expects market participants to do better when it comes to sustainability claims. The AFM will pay extra attention in 2026 to ensuring that sustainability claims are fair.
This publication follows an exploratory study by the AFM of several financial institutions in 2024 and 2025 in which the AFM investigated sustainability claims and use of its Guidelines on Sustainability Claims for financial institutions and pension providers, which were published in 2023. In its study, the AFM found that there is room for improvement in four areas where financial institutions should take extra steps. This blog discusses these four areas.
The AFM expects market participants to further improve their sustainability claims where necessary in the following four areas:
- Ensure that sustainability claims are factually accurate and representative
- Specify what a sustainability claim means for the market participant or the product.
- Ensure that substantiation is easy to find.
- Provide necessary explanations for claims on climate neutrality, ESG ratings and impact
1. Accuracy and representativeness
Claims that are not representative may create an impression of greater sustainability than is actually the case.
Institutions should communicate both the positive and negative aspects of a product's sustainability impact in an even-handed manner. Minor benefits should not be highlighted in a way that obscures the broader picture of an institution's overall sustainability efforts.
The practical implication is straightforward: sustainability labels and green product classifications must faithfully reflect the full scope of what is being financed or invested in, not merely the most favourable elements. Where a product exhibits mixed characteristics, full and accurate disclosure of those characteristics is required.
2. Specify sustainability claims
Clear and specific language should be used to indicate what a company or product is doing in terms of sustainability. If a claim cannot be substantiated, it should not be made.
Where information is presented in layers, each layer must independently be correct, clear and not misleading.
This requirement directly affects how sustainability claims are communicated publicly. For example, website descriptions of an ESG or sustainability-linked performance must be clear, specific and substantiated.
3. Accessibility of substantiation
All relevant information related to sustainability claims must be easily accessible. Information should not be obscured by irrelevant information.
The AFM's findings in its study indicate that supporting information is frequently hard to locate. In some cases it is entirely absent; in other cases it is separated from the claim by several layers of navigation, or embedded within documents of considerable length that are only partially relevant to the assertion being made.
The implications for how ESG disclosures are structured and cross-referenced in external communications are considerable: accessibility is not merely a presentational preference — it is a regulatory expectation.
4. Provide explanations for climate neutrality, ESG Rating and Impact claims
Climate neutrality
Where a market participant articulates medium- to long-term sustainability objectives — particularly commitments to achieving climate neutrality — it must provide a sufficiently detailed account of how those objectives are to be met. A commitment that specifies only an end date does not enable the reader to evaluate its credibility or ambition.
ESG ratings and scores
Where sustainability claims draw upon third-party ratings, scores or certifications, market participants must contextualise those references by explaining the nature and scope of the underlying assessment, the methodology on which it is based, the scale against which the rating is expressed, and the identity of the issuing body. Furthermore, such references carry an ongoing obligation of maintenance: outdated scores or superseded certifications must be updated promptly to avoid creating a misleading impression.
Impact claims
Impact claims may only be made where there is actually additional, intentional and measurable impact, and market participants must explain how the investor creates that impact.
