AFM Analysis Report: Research on Sustainability among Property and Casualty Insurers

ANALYSIS REPORT Research on Sustainability among Property and Casualty Insurers APRIL | 2026

© AFM 2026 | Research on Sustainability among Property and Casualty Insurers 2 Key Findings • Insuring new (sustainability) risks presents challenges • Insurers state they play a key role in greening society • Sustainability ambitions are concretely translated into insurance products • Insurers report many sustainability features on retail products, fewer on commercial ones • There is room for improvement in measuring the impact of sustainability features • AFM sees good sustainability initiatives and will continue to monitor sustainability Property and casualty insurers are seriously addressing sustainability, but still face challenges. Almost all insurers state that their sector is a crucial link in the energy transition. The AFM observes in its research among property and casualty insurers that they are also fulfilling this role. Many sustainability features are reported for retail products, but fewer for commercial ones. We see room for improvement in measuring the impact of the sustainability features that insurers attach to their products. The AFM sees good sustainability initiatives We see that insurers are seriously working on the sustainability theme and collaborating to create greater impact. They do this, for example, on the topic of sustainable claims repair and by introducing standards to measure the CO2 emissions of their portfolio. This can lead to reliable, easily comparable measurements and a uniform interpretation of certain terms. The AFM therefore encourages the sector to continue designing and implementing such initiatives. The AFM examined the sustainability features of property and casualty insurance The AFM conducted research into sustainability features among a large number of property and casualty insurers. This gave us insight into how these insurers are implementing sustainability. We asked insurers to report on the sustainability features in their products, underwriting processes, and other activities. By sustainability feature, we mean any element of an insurance product or process that relates to sustainability. Examples include underwriting conditions, preventive measures, or specific coverages. Insurers themselves decide which elements they consider sustainability features. Insurers signal their important role, but also challenges in greening society Almost all insurers state that the insurance sector is a crucial link in the energy transition. Some insurers also see themselves as leaders in insuring the sustainability transition, and they make sustainability a key pillar in their own strategy. Insuring the new risks that arise in a market like the sustainability market presents challenges. These risks are often new and unknown, and it is therefore not easy to price them. This ranges from the fire risk of a home battery to the entire risk of a hydrogen plant. The sector also notes this in its recent 'position paper on the insurability of the energy transition in the commercial market'. In it, the Association of Dutch Insurers states that insurers are taking action on this, for example when insuring large quantities of solar panels. The AFM views this positively, as the insurance sector is needed to enable the energy transition.

© AFM 2026 | Research on Sustainability among Property and Casualty Insurers 3 Our research also shows that property and casualty insurers incorporate a wide range of sustainability features in their products, underwriting processes, and other activities, but that there are also market challenges. Insurers report many sustainability features for retail products, fewer for commercial ones The research shows that consumers can currently insure common new risks, such as home batteries. Most sustainability features relate to the retail market. 36% of all reported features apply exclusively to retail insurance, and 35% to both retail and commercial products. 15% of the features apply exclusively to commercial products. Given the importance of insuring commercial initiatives to enable the energy transition, the AFM had expected insurers to report more features on the commercial side. We do see insurers taking various initiatives in this area, such as insuring hydrogen refueling stations and insuring bio-based construction methods. There is room for improvement in measuring the impact of sustainability features The research shows that insurers rarely measure the impact of a specific feature on sustainability. This happens in less than half of cases. In 59% of cases where insurers state they measure impact, they only measure the usage of a specific feature. Insurers measure, for example, how many customers receive their policy terms digitally, but state they do not measure how much CO2 emissions are saved thereby. Without insight into the actual impact of certain sustainability features, it is more difficult to substantiate how a feature contributes to sustainability. Disclosure standards require that insurers' sustainability claims are accurate, clear, and not misleading. The AFM's Sustainability Claims Guide provides insurers with guidance on how to do this well based on three principles (accurate, representative & current; concrete & well-substantiated; and understandable, appropriate & accessible). The AFM's ESG update on sustainability claims from January 2026 emphasizes that sustainability claims must be concrete and well-substantiated. The AFM continuously monitors sustainability Sustainability remains an important theme for the AFM. We will continue to focus on this topic in the coming years, and may conduct new research into how property and casualty insurers are implementing sustainability.