ANALYSIS REPORT

DECEMBER 2025

Towards Transparent Reporting on Climate Transition Plans and Financed Emissions

In Short

Major Dutch financial institutions have committed to climate goals. In their sustainability reports, they provide insight into their transition plans and financed emissions. This information must not only be relevant, reliable, and understandable, but also enable good comparison between market participants, so that users of the report can make informed decisions. This report provides a current picture of the reporting on climate transition plans and financed emissions by major Dutch banks and insurers, and offers development points for the sector.

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ANALYSIS REPORT

Market Overview and Four Development Points 3

1. Financed Emissions 7
2. Development Points for the Financial Sector 9
3. Banks 11 3.1 Reporting on Emission Figures 11 Market-wide Observations 11 Observations on Reporting of Emission Figures 18 3.2 Transition Plans 19 Market-wide Observations 19 Observations on Reporting of Transition Plans 22 3.3 Development Points for Banks 23
4. Insurers 25 4.1 Reporting on Emission Figures 25 Market-wide Observations 25 Observations on Reporting of Emission Figures 31 4.2 Transition Plans 32 Market-wide Observations 32 Observations on Reporting of Transition Plans 34 4.3 Development Points for Insurers 34
5. Data Quality 35 Appendix 1 – Annual Reports and Transition Plans 37 Appendix 2 – List of Abbreviations 38 Table of Contents

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Market Overview and Four Development Points

1. See: https://klimaatcommitment.nl/

Climate Transition and the Role of the Financial Sector

The transition to a sustainable society is one of the most important challenges of our time. Financial institutions mobilize capital for sustainable investments by governments, businesses, and households, and contribute to the greening of companies by steering towards sustainability aspects in business operations. The AFM attaches importance to this transition and encourages financial institutions to fulfill their important role in it.

In the Paris Agreement, countries agreed to drastically reduce greenhouse gas emissions to limit global warming to well below 2°C, and preferably to a maximum of 1.5°C compared to pre-industrial levels. The Netherlands has committed to this and has enshrined it in the Climate Act, with the goal of reducing emissions by 55% in 2030 compared to 1990. These objectives have been further elaborated into sector-specific reduction targets for, among others, industry, mobility, agriculture, and the built environment.

Dutch financial institutions have also committed to climate targets. In 2019, approximately fifty financial institutions signed the Climate Commitment of the financial sector.1 A key component of this commitment is drawing up action plans with concrete reduction targets for 2030 and an explanation of their contribution to the Paris Agreement. With the introduction of the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), these action plans have been integrated into the sustainability report, which is part of the annual report.

The CSRD and ESRS stipulate that institutions that have a climate transition plan must be transparent about it in their annual report. Because in that climate transition plan, institutions make clear how they contribute to achieving the goals of the Paris Agreement. Institutions must not only mention long-term goals, but also formulate concrete intermediate targets. They must also provide insight into financed emissions and explain which strategy they follow for reducing emissions, which levers they use, and how they measure the progress of the transition plan.

An important starting point of the CSRD is that the information provided must not only be relevant and reliable, but also understandable, and that the information allows for good comparison between market participants. Users of the report – such as investors, NGOs, consumers, and regulators – can then assess and compare the impact, risks, and opportunities of institutions regarding the climate and their transition plans. The reporting thus provides important insight into the strategic choices of institutions in their contribution to the climate transition.

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ANALYSIS REPORT

Sustainability Reporting: A Joint Learning Process

The CSRD had not yet been implemented in Dutch legislation at the time of this research; institutions that have a climate transition plan and reported on it in their 2024 annual report did so on a voluntary basis. Sustainability reporting according to the new CSRD regulations is a learning process. For all parties involved in the annual report, including the institutions themselves, but also for audit firms, investors, NGOs, and regulators, including the AFM. The AFM does not yet formally supervise CSRD reporting, but is preparing for it by looking at the sustainability reports that have already been drawn up according to the CSRD and the underlying ESRS regulations. This is done, among other things, through this exploration of the market status.2

The AFM conducted research into climate reporting and the explanation of the climate transition plan in the 2024 annual report for four major Dutch banks and four major Dutch insurers.3 The sustainability reports of these institutions were drawn up for the first time in line with the new rules, as laid down in the CSRD and the ESRS. All institutions investigated signed the Climate Commitment in 2019. In this exploration, we focus exclusively on financed emissions (not facilitated or insurance-related emissions or emissions from own operations) and the associated transition plan.

2 On February 26, 2025, the European Commission published proposals for simplifying existing sustainability legislation, including the CSRD. The so-called Omnibus Proposal proposes changes to the scope and phasing of CSRD reporting obligations. Adjustments to the reporting standards are also being worked on. The current standards are 'sector-agnostic' and apply to all companies. Under the CSRD, it was originally intended that 'sector-specific' standards would also be introduced, with specific requirements for different sectors, including the financial sector. However, the Omnibus Proposal announces that these sector-specific standards will not be established. At the time of writing this report, no political agreement has been reached on the Omnibus Proposals. As a result, it remains uncertain what the final scope and content of the reporting standards under the CSRD will be.

3 The selected parties are ABN AMRO Bank (ABN AMRO), ASN Bank, ING Group (ING), Rabobank, Achmea, a.s.r., Athora Netherlands (Athora), and NN Group (NN). These eight parties were selected for the research because they belong to the largest Dutch financial institutions and fall within the scope of the CSRD.

With this exploration, the AFM not only wants to gauge the state of the market, but also contribute to the further maturation of reporting on financed emissions and the transition plan in the sustainability reports of financial institutions.

The market is already moving in the right direction, we see. With the insights from this exploration – summarized in market images and concrete development points, both generally and per sector – parties can take next steps in their sustainability reporting.

Enterprises can use the development points for further deepening and standardization of sustainability reporting. The quality characteristics of relevance, faithful representation, comparability, verifiability, and understandability from the CSRD and ESRS serve as the starting point. In this way, users of the report can assess and compare the impact, risks, and opportunities of institutions regarding the climate and the transition plans. The reporting is thus not only a compliance effort; it forms the culmination of the strategic search of institutions for their contribution to the climate transition and provides the user of the report with insight into the strategic choices institutions make in this regard.

Market Image and Development Points

The report now in your hands outlines a current picture of the way the investigated parties provide information on financed emissions and climate transition plans in their 2024 annual reports. In doing so, we looked at the manner in which financial institutions report on this, the depth of the reporting, the manner in which institutions explain their progress, and the extent to which this information is comparable among each other.

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Market Overview at a Glance

Standardized sustainability reporting is a development trajectory, where institutions are now taking the first steps. Further attention is needed to strengthen the coherence, depth, and standardization so that the user of the report can follow the progress of the transition plan well.

All investigated banks report in their annual report on their transition plan and intermediate goals, but the scope and depth still differ considerably. For banks, the financed emissions of business loans are primarily relevant, as these form by far the largest source of emissions. In addition, banks provide insight into the sectors they finance and the objectives and plans per sector, but consistency within and between annual reports is still lacking. Reports still show great variation in definitions, scopes, and measurement methods, making comparability for users limited.

The investigated insurers present their emission figures in a consistent manner, but the transition plans are still limited in comparability. Corporate and government bonds represent the largest share of emissions. The plans focus primarily on financed emissions from their own investments. Comparability between insurers is limited due to differences in scope, measurement units, and reporting formats. Additional information on greening is often provided outside the annual report.

All investigated institutions state that data quality in the chain is an important bottleneck. Uncertainties arise from the limited availability of primary data at financed companies, especially further down the value chain. Institutions are therefore forced to make frequent use of estimates, models, and external data providers. Obtaining reliable and recent data from parties deeper in the value chain is more complicated than from direct counterparties. The AFM therefore focuses primarily on financed scope 1 and 2 emissions for the market overview in this report.

The AFM encourages the sector to continue working on a more standardized approach. The AFM therefore provides some development points for the entire sector.

Four Development Points

1. Deepen the reporting of financed emissions to sectoral breakdown and increase insight into the contribution of the institution to the greening of the real economy. Report not only at portfolio level, but also at sector level with physical intensity targets and sector-specific greening targets.
2. Increase insight into what is and what is not in scope of the plan. Explicitly state which parts of the portfolio fall under the transition plan and which do not, and link this information to the financing in euros and the reported financed emissions.
3. Improve consistency in definitions and measurement units within the annual report and between institutions. Use consistent definitions and measurement units, and harmonize market-wide the handling of government bonds, scope 3 data, and sector classifications. Continue the initiatives and cooperation already initiated at the industry level, in the Netherlands, and where possible at the international level, for further standardization.
4. Take the perspective of the user into account and strengthen the coherence between reporting on emission figures and the transition plan. Ensure, for example, logical placement of information and a clear link in the sustainability report between the (total and broken down) emission figures, and the transition plans, so that the user gains insight into the coherence between the two.

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Reader's Guide

Chapter 1 gives a short explanation of the meaning of the concept 'financed emissions'. In Chapter 2, we zoom in on the development points that the AFM provides to the sector as a whole. In Chapters 3 and 4, a market overview is sketched for banks and insurers respectively, based on the information in the annual report, and market-wide observations are shared regarding the manner in which the institutions report. Here, specific development points are formulated for the respective sector. In Chapter 5, we finally address the uncertainties in data quality and the manner in which institutions provide insight into this.

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1. Financed Emissions

Financed emissions are the greenhouse gas emissions that arise from the activities of customers or companies in which a financial institution invests or to which it provides credit. These emissions are not caused by the financial institution itself, but are a consequence of its financial services. Banks and insurers generally report on their financed emission figures per asset class. Asset classes in reporting usually consist of loans, shares, bonds, mortgages, and/or real estate investments, but can differ in precise definition and scope per institution.

In the 2024 annual reports, financial institutions report their climate progress not only in terms of absolute financed emissions. They also use additional measurement units that provide more context regarding the nature and intensity of these emissions. Two commonly used measurement units are 1) economic intensity and 2) physical intensity of emissions.

• Economic intensity: This is the amount of emissions per invested or financed euro, for example expressed in tons of CO2e (carbon dioxide equivalent) per million euros. This metric makes it possible to relate emissions to the size of the financial exposure and is useful for comparing institutions with different balance sheet sizes. It helps to assess how emission-intensive a portfolio is in relation to the invested amount.
• Physical intensity: Here, emissions are related to physical output, such as kilograms of CO2 per square meter of real estate, per megawatt-hour of energy, or per ton-kilometer of transport. This metric provides insight into the sustainability performance of the underlying economic activities and is particularly relevant for sector-specific transition plans. Physical intensity is thus a direct indicator of the degree of greening in the real economy.

As the ESRS prescribes, institutions distinguish between financed scope 1 and 2 and scope 3 emissions and report on the emission intensity of their financing. When we speak in this report about scope 1 and 2 and scope 3 emissions, we mean the emission figures based on financed emissions, i.e., of the companies that the financial institution finances or invests in.

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Scope 1, 2, and 3 Emissions for Financial Institutions

In reports on CO2e emissions, a distinction is made between scope 1, 2, and 3 emissions. Below is an explanation of what these scopes mean precisely for financial institutions.

Scope 1 Direct emissions in own operations. Example: Emissions that the company itself causes, for example through gas usage in own buildings, driving company cars, or running machines.

Scope 2 Indirect emissions via purchased energy. Example: Emissions that arise because the company purchases electricity or heat, for example for lighting, computers, air conditioning, or production equipment.

Scope 3 Indirect emissions via suppliers and product usage. Suppliers ('upstream'): Example: Emissions during the extraction and transport of raw materials and components by other companies. Product usage ('downstream'): Emissions during the use of the product by customers, during maintenance, and during disposal or recycling of the product.

In this scope falls the emissions of customers that the institution finances or invests in (financed emissions) ... This is the direct and indirect emissions of the financial institution: mainly as a result of office activities. ... and these customers in turn also have their own Scope 1, 2, and 3 emissions. These emissions are included in the reports of the financial institution, and are by far the most interesting: this is where the most profit can be made when it comes to reduction targets.

Scope 1 Direct emissions in own operations. Relatively small for financial institutions.

Scope 2 Indirect emissions via purchased energy. Relatively small for financial institutions.

Scope 3 Financed emissions (and other indirect emissions from the chain). Relatively large for financial institutions.

! In our report, we only look at these Scope 1, 2, and 3 emissions.

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2. Development Points for the Financial Sector

4 ESRS-1 Appendix B: Qualitative characteristics of information KK1 to KK20.

The 2024 annual reports are an important first step in the implementation of the CSRD. All investigated banks and insurers have drawn up transition plans with concrete intermediate goals for 2030. They provide information on financed emissions at the level of (composite) asset classes and provide insight into the transition plan and progress regarding it. In many cases, institutions have been reporting on this for a number of years, often in separate documents specifically about the transition plan. This also creates an extra challenge for institutions: adapting existing reporting practices to the new requirements of the CSRD. Reporting according to CSRD standards is therefore still in a development phase: institutions are taking good first steps, but the depth and consistency of the information still differ within the report and between institutions.

In the 2024 sustainability report, many institutions initially focus on meeting the reporting requirements, including reporting financed emissions. Banks primarily impact financed emissions through the loans they issue and investments they make. Financed emissions thus provide insight into the emissions of the customers financed by the financial institution and are therefore a relevant indicator for the reader of the annual report. This gives an image of the challenges and opportunities the institution faces regarding the transition. The CSRD stipulates that reporting must be done at the level of asset classes or sector. At the same time, this indicator also has limitations as a measure for the role financial institutions play in the greening of the real economy. For a good understanding of the climate position of institutions, deeper information is also needed, such as sector-specific goals and indicators that make the impact of financing in the real economy visible. For this reason, many institutions also (partially) report on physical intensity targets at the sectoral level. However, the provision of deeper sectoral information is often done in disparate ways.

The AFM encourages the sector to continue working on a more standardized approach. Differences in definitions, scope, measurement units, and measurement methods currently still complicate comparability between institutions. Also within individual annual reports, coherence between emission figures and transition plans is sometimes lacking. This makes it difficult for users to assess the progress and ambition of institutions. We therefore formulate some development points for the financial sector, in line with the qualitative characteristics of the sustainability report required by the ESRS: relevance, faithful representation, comparability, verifiability, and understandability.4

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ANALYSIS REPORT

1. Deepen the reporting in the annual report to sectoral breakdown and increase insight into the contribution of the institution to the greening of the real economy.

Report not only per asset class, but provide insight into financed emissions at sector level, including sector-specific greening targets and physical intensity indicators. Banks show a mixed picture in this: some provide detailed sectoral information with physical intensity targets and additional explanation, while other banks provide this insight only briefly or limit it to those parts of sectors for which a transition target has been established. Insurers generally provide less depth, making the link with actual greening in the economy limitedly visible in the reporting. A number of insurers do provide this deeper information outside the annual report, in a separate document about the transition plan. Such deeper information provides relevant interpretation for the user of the report regarding the role of the institution in the greening of the real economy and thus the achievement of climate goals.

2. Increase insight into what is and what is not in scope of the plan.

Explicitly state which parts of the portfolio fall under the transition plan and which do not, including the associated emissions. In current reporting, this is often not entirely clear. For example, with banks, it is not always clear in an overview which part of the loan portfolio actually falls under a concrete transition target, and what exactly does not fall under it. Also with insurers, it is not always immediately clear which part of the investments is in scope and what remains out of scope, or on which indicators exactly the transition plan is based.

(Note: The provided text ends abruptly at this point.)