Dutch Regulator Steps Up Pressure on Sustainability Claims in Finance

Key Takeaways

• Sustainability Claims Shape Expectations: The AFM stresses that sustainability claims are not just marketing language but narratives that influence how consumers and pension participants assess products and institutions.
• Guidelines Are Used, But Gaps Remain: While most financial firms reference sustainability claim guidelines, vague wording and weak explanations still undermine clarity and credibility.
• Substantiation Is Often Hard to Find: The regulator found that supporting evidence for claims is sometimes missing or buried far from the original statement, increasing the risk of misunderstanding.
• Four Areas Need Immediate Attention: The AFM highlights factual accuracy, clear explanation of what claims mean in practice, accessible substantiation, and stronger clarification around climate neutrality, ESG ratings, and impact.

Deep Dive

Sustainability claims are not just marketing copy. They tell a story, set expectations, and shape how consumers and pension participants decide where to place their money. That is what the Authority for the Financial Markets (AFM) said in a recent study, which is calling on financial institutions to sharpen the accuracy and clarity of how they communicate their sustainability ambitions.

In a new ESG update, the Dutch watchdog outlines four key areas where sustainability claims across the financial sector still need improvement. The findings are based on an exploratory study of claims made by banks, insurers, investment firms, and pension providers, and come as the regulator signals closer supervisory attention in 2026.

According to the AFM, the financial sector plays a central role in the transition to a more sustainable society. For that role to work effectively, consumers and pension participants need clear and fair information that allows them to form realistic expectations.

When sustainability claims are specific and well substantiated, the regulator notes, they tend to be more credible and make it easier for people to choose products and institutions that genuinely align with their values. Vague or overly broad claims, by contrast, increase the risk of confusion and disappointment.

What The AFM Found In Its Review

The AFM examined sustainability claims from twenty financial market participants and assessed how they align with the principles set out in the Guidelines on Sustainability Claims. The regulator found that firms are generally using the guidelines, but that does not automatically translate into clear communication.

One recurring issue was the tension between marketing language and meaningful explanation. Statements such as “we believe a sustainable world is important” or “our investments take society into account” may sound positive, but they often lack detail about what a firm actually does or achieves. In the AFM’s view, such wording raises expectations without giving readers a concrete basis for understanding the underlying actions or results.

Substantiation was another weak spot. In some cases, supporting information for sustainability claims was missing entirely. In others, it existed but was hard to find, buried far from the original claim or located in sections of websites or reports that consumers are unlikely to navigate. The regulator did note that it also observed examples of good practice, showing that clearer and more transparent claims are achievable.

Four Areas Where Claims Need Improvement

Based on the study, the AFM has identified four areas where market participants should focus their efforts.

Sustainability claims should first be factually accurate and genuinely representative of a firm’s activities or a product’s characteristics. Firms should also clearly explain what a claim actually means in practice, both for the institution itself and for the specific product being offered.

In addition, substantiation should be easy to find and closely connected to the claim it supports, rather than hidden elsewhere. Finally, the AFM says that claims involving climate neutrality, ESG ratings, or impact require additional explanation so that readers can understand how those terms are defined and applied.

The regulator has expanded on these areas in its third ESG update, including practical examples of both strong and weak claims.

The AFM said the institutions involved in the study indicated they would use the findings to reassess their sustainability claims, and some have already made changes. But the regulator made clear that expectations will only increase.

Sustainability remains a strategic priority for the AFM, and in 2026 it plans to carry out another review of sustainability claims across the sector. The standard, the watchdog said, is that all claims must be correct, clear, and not misleading, or balanced in the case of pension products.

The principles in the Guidelines on Sustainability Claims and the latest ESG update are intended to support firms in meeting those expectations. For market participants, sustainability claims need to move beyond broad aspirations and be grounded in clear, specific, and accessible information that allows consumers and pension participants to make informed choices.

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