Fair Sustainability Claims: What Does the AFM Expect from You?

SUPERVISION ESG UPDATE 3 JANUARY 2026 Fair Sustainability Claims: What Does the AFM Expect from You?

In Brief In 2024 and 2025, the AFM conducted a scoping study on sustainability claims by financial market participants. We examined how these align with the principles of the Sustainability Claims Guide. We observe that market participants are using the guide, but there is particularly room for improvement regarding the specificity of claims and the findability of the supporting evidence. To further assist the market, this update shares the four most important areas for improvement – including good and bad examples. We also outline the key findings from our scoping study. Next year, we will more prominently supervise that sustainability claims are fair. We expect market participants to further sharpen their sustainability claims where necessary.

The 4 Most Important Areas for Improvement 1 See the information disclosure standards in the Sustainability Claims Guide for the legal framework. 2 Research: Consumer Perception of Sustainability Claims, ACM 2023. 3 The examples are inspired by sustainability claims from the scoping study and have been aggregated and anonymized. In practice, we always conduct a case-specific assessment.

Colours, images, words – consumers quickly form an impression. A sustainability claim is therefore more than just text on a website or in an advertisement: it is a story that creates expectations. A sustainability claim must be correct, clear, and not misleading (or for pensions: balanced).1

The AFM observes that marketing language clashes with clear and concrete explanations, and that supporting evidence is frequently difficult to find. Our scoping study also shows that it is indeed possible for financial market participants to comply with legal requirements. The financial sector plays an important role in the transition to a sustainable society. Clear and fair information on sustainability ensures that consumers and participants have the right expectations. Consumers find concrete and well-substantiated claims more credible.2

The scoping study conducted by the AFM in 2024 and 2025 among banks, insurers, investment firms, and pension administrators reveals four areas where improvement is needed. We support these improvement points with examples.3

The four most important areas for improvement:

1. Ensure that sustainability claims provide an accurate image and are representative.
2. Make concrete what a sustainability claim means for the market participant or the product.
3. Ensure that the supporting evidence is findable.
4. Provide necessary explanations for claims regarding climate neutrality, ESG ratings, and impact.

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1. Ensure that sustainability claims provide an accurate image and are representative 4 In the sense of information disclosure standards as addressed in the Sustainability Claims Guide

Consumers must be able to trust that information is correct. Incorrect claims are not correct4 and may be misleading. If claims are not representative, consumers may form an impression of greater sustainability than actually exists and purchase a product that does not align with their preferences. Non-representative claims may be unclear and/or misleading.

Additional guidance on this improvement point • Be accurate: ensure the claim is substantively correct and contains no contradictions. Regularly verify that the information remains accurate. Also remain alert to consistency within and across information carriers. • Be transparent: describe both the positive and negative aspects of the sustainability impact. Honest communication strengthens trust. • Be honest about efforts made: do not emphasize minor benefits to consumers if they do not provide a representative picture of sustainability efforts. • Use realistic imagery: only use images that give a truthful impression of the situation. Place images in an appropriate context. • Pay attention to the overall impression: carefully consider how text and images combine. Ensure claims sketch a balanced picture.

Good Examples | Bad Examples Sustainable Investments | Total Investments “With our investment product, you invest in the most sustainable companies in their sector. Be aware that this means we do not only invest in wind turbines, but also in the most sustainable companies in the oil and gas sector.” | “This financial product never invests in companies that cause animal suffering.” However, the terms and conditions show that investment can still be made in companies that derive up to 5% of their revenue from the sale of products that cause animal suffering. For a financial product, images are included of projects financed by this product that provide a representative picture of where the product is invested. | “Last year we invested EUR 14 million in sustainable products.” It is not mentioned that this represents only 10% of the total invested amount. | No animal suffering

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2. Make concrete what a sustainability claim means for the market participant or the product

Vague descriptions or sustainability claims that do not include all necessary information can present a wrong, unbalanced, or incomplete picture of the market participant or the product. Non-concrete claims can be unclear and/or misleading.

Additional guidance on this improvement point • Avoid vague language: use clear and specific language to indicate what your company or product does regarding sustainability. Consumers find concrete claims more understandable and credible. • Provide relevant context: provide all information necessary to understand the claim. Use (representative) examples where needed to concretize a claim. • Substantiate sustainability claims: if a claim cannot be substantiated, do not make the claim. • Present information in layers if necessary: first provide a core message and give additional explanation where needed. Ensure that each layer of information is, on its own, correct, clear, and not misleading (or balanced). Even if a reader does not click further, the claim must sketch a fair picture. • Place the supporting evidence as close to the claim itself as possible, so that the claim independently meets the relevant information disclosure standards.

Good Examples | Bad Examples A company provides insight into how money is invested, with concrete and representative examples of projects in which it has invested. | It is not made clear whether the company supports this ambition with concrete actions. A company has placed an infographic on its website that visually shows in which sectors the raised funds have been invested. | The company does not make clear what this is based on. | 1 3 2 We are one of the most sustainable pension funds in the world. | % WE FIND A SUSTAINABLE WORLD IMPORTANT.

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3. Ensure that the supporting evidence is findable

Ensure that relevant information regarding the sustainability claims is easily findable. Information must not be buried by non-relevant information. If information is poorly findable, it can render the information unclear.

Additional guidance on this improvement point • Put yourself in the reader's shoes: ensure that information relevant to understanding the claim is easily and quickly findable without requiring too many clicks. This can be done, for example, by linking directly in the claim itself, using pop-ups, or infographics. • Ensure a good structure: if you refer to long documents, such as an annual report or an investment policy, it is useful to provide the reader with pointers to quickly find the relevant passages. • Also ensure that the explanation is relevant to substantiating the claim: long texts that are not relevant to substantiating the claim can be confusing and carry the risk that the reader cannot properly assess the claim. It is important that there is a clear link between the claim and the supporting evidence. • Check if supporting evidence is available: are all referenced documents actually on the website and easily findable?

Good Examples | Bad Examples “The premium for this insurance is invested according to our sustainability policy.” If the reader clicks on the word ‘sustainability policy’, they are immediately directed to relevant parts of the sustainability policy. | A company claims to take biodiversity into account in investment decisions. For substantiation, it links to a 200-page sustainability policy, of which only four pages discuss biodiversity. There is no clear table of contents, making it difficult for the reader to find this information. A company substantiates its claim with a long, English-language document. To help the reader, a Dutch summary is included. | To find relevant substantiation, a customer must first click from the claim on ‘More information’, ‘Frequently Asked Questions’, ‘What are our ambitions?’, and finally on ‘Read more about how we pursue our goals’. | sustainability policy Click for the Dutch summary BIO CLICK

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4. Provide necessary explanations for claims regarding climate neutrality, ESG ratings, and impact

In our scoping study, we noticed that for claims regarding climate neutrality, ESG ratings, and impact, information is often missing that the reader needs to properly assess such claims. Therefore, we provide extra guidance on these topics.

Additional guidance on this improvement point • For sustainability claims regarding (medium) long-term goals, such as climate neutrality, make it clear how these goals will be achieved. Provide or refer to information necessary to understand the claim. The following non-exhaustive list of questions can be used for support:

• what the company means by ‘climate neutral’ (for example, only CO2 or also CO2 equivalents or other greenhouse gases);
• how much emissions the company had in the base year and what year that was;
• how much emissions the company currently has (what is the progress);
• what the company's ambition is regarding the ratio between how much emissions are reduced and how much is compensated;
• in what way the company compensates for the remaining emissions (is this (partially) based on uncertain or unproven technologies);
• what interim goals the company sets and what actions the company links to them. • For sustainability claims linked to third-party assessments or certifications (such as labels, ESG ratings, or scores), explain what this assessment or certification means. Also indicate what it is based on, what scale the rating or score operates on, and who prepared it. Also ensure that a reference to such scores is up to date. • For impact claims: only make such claims if there is actually additional, intentional, and measurable impact. Explain how the investor creates impact.

Good Examples | Bad Examples 2025 received certificate for ? ? | A bank states its goal to be climate neutral by 2050. It is not explained in which specific year the goal must be achieved, how this goal will be achieved, or what the progress is. A reference to a certification on the website, clearly showing for which year the certification applies and what the certification entails. | “If you choose to invest with us, you contribute to improving biodiversity.” It is not explained how the investor creates additional impact. An investment firm explains for each model portfolio how the investments contribute to the stated sustainability goals and reports on this periodically. | A B C

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Key Findings from the Scoping Study

In the scoping study, we assessed the quality of sustainability claims on the websites of financial market participants based on the principles of the Sustainability Claims Guide. The study focused on 43 sustainability claims from twenty banks, insurers, investment firms, and pension funds.

Many sustainability claims currently insufficiently concrete; risk of mismatch Our scoping study shows that many sustainability claims are currently insufficiently concrete. They often contain vague phrasing, making it unclear what is precisely meant by the claim. Think, for example, of statements like “We find a sustainable world important” or “Our investments pay attention to society”. Such wording is vague and does not provide a clear picture of the actual efforts or results. At the same time, these statements do create expectations in the reader. The risk of a mismatch is high.

Substantiation of many claims difficult to find Furthermore, we observe that the substantiation for many claims is difficult to find. In some cases, the information is completely unavailable; in other cases, the information is located far from the claim – often requiring the reader to click through – or the supporting information is placed in a location that is difficult to find in another way. For example, in a document of dozens of pages, not all of which are relevant to the claim.

Financial market participants are taking extra steps Our scoping study also shows that financial market participants are taking steps to improve their communication. We discussed the findings of the scoping study with all investigated companies. Many parties indicated in these discussions that they use the principles of the Sustainability Claims Guide in their communication. Furthermore, they stated they would re-examine the claims in light of the scoping study findings. Additionally, some of the investigated parties have already adjusted their claims, either in response to our findings or on their own initiative – before we contacted them. In several cases, the investigated claim was incorrect, and we identified a violation. These claims have since all been adjusted.

What is the AFM Doing? Sustainability in the financial sector is a strategic priority for the AFM. In 2026, the AFM will conduct another study on the quality of sustainability claims. The AFM expects all claims to be correct, clear, and not misleading (or balanced). The principles from the Sustainability Claims Guide and the improvement points from this ESG update support the sector in this regard. We expect market participants to further sharpen their claims where necessary.

Do you experience bottlenecks or areas for improvement in the market? Please email ESG-update@afm.nl. We will answer your messages where possible and use them to map out the most significant bottlenecks. The AFM will provide as much clarification as possible by further supplementing our information. More information can be found on our Sustainability page.