Dutch Regulators See Early Progress as Banks & Insurers Begin Climate Transition Reporting

Key Takeaways

• First CSRD-Aligned Reporting: Major Dutch financial institutions are publishing climate transition plans and financed-emissions data in line with CSRD standards for the first time.
• Banks Focus on Corporate Lending: Banks disclose sector-specific emissions and interim climate targets, but reporting scope and methodologies vary widely.
• Insurers Focus on Investment Portfolios: Insurers report emissions by asset class, though transition plans remain uneven and sometimes spread across multiple documents.
• Data Quality Challenges: Institutions rely heavily on estimates and external models due to limited value-chain emissions data.
• Sector Needs Standardization: AFM urges greater consistency so stakeholders can assess and compare climate alignment and progress.

Deep Dive

Dutch financial institutions are beginning to show how they plan to align their business with a climate-safe future, and regulators say the early progress is encouraging, even if the road ahead is long. In a new review, the Netherlands Authority for the Financial Markets finds that eight of the country’s largest banks and insurers are reporting on their climate transition plans and financed-emissions data in a more structured and transparent way than ever before.

What makes this particularly notable is that they’re doing it voluntarily. The EU’s Corporate Sustainability Reporting Directive (CSRD) isn’t yet embedded in Dutch law, but institutions have already started publishing sustainability reports that follow its standards.

The AFM frames this moment as an important shift. Financed emissions, the emissions tied to loans and investments, make up the bulk of the financial sector’s climate impact. By explaining how they will reduce those emissions in line with the Paris Agreement, banks and insurers offer real insight into whether their capital is accelerating the transition or quietly working against it.

Early Reporting Shows Promise but Also Growing Pains

This first round of reporting is described as a genuine learning process not just for the institutions preparing the disclosures, but also for auditors, investors, and regulators who will soon supervise them. The AFM’s review aims to speed that learning curve by highlighting where reporting is already adding value and where comparability still falls short.

Banks generally offered more detailed emissions reporting and set interim climate targets, especially around corporate lending—the biggest driver of their financed emissions. Some even broke out plans across the sectors they finance. But because the scope and methodologies vary from bank to bank, comparing their progress remains harder than it should be.

Insurers are further along in reporting emissions by asset class, particularly corporate and sovereign bonds that dominate their portfolios. Yet their transition plans remain uneven in clarity and format, and sometimes key details sit outside the annual report, making them harder to track.

Standardization and Better Data Will Define the Next Phase

Every institution reviewed raised the same stumbling block of data quality. The further they look into the value chain, the more uncertainty shows up in the numbers, especially when they rely on modeling rather than verified, company-level emissions data. Institutions say solving the data challenge is essential to making transition planning meaningful.

The AFM sees momentum. Banks and insurers are already participating in national and international efforts to harmonize approaches, and the regulator wants to see that continue. Aligning definitions, scope boundaries, and how emissions really connect to transition strategies will be key to holding institutions accountable for impact, not optics.

For now, the regulator is taking the glass-half-full view. Dutch financial institutions have pledged action for years. Now, those climate promises are beginning to appear in annual strategic reporting that investors and the public can scrutinize, right where they belong.

The direction is right, but the challenge now is consistency, credibility, and keeping climate action central to the financial decisions that shape the real economy. Because transparency in reporting isn’t just about compliance. It’s about proving that finance is playing its part in the transition the world urgently needs.

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