Fair sustainability claims: 4 areas for improvement for market participants

Clear and fair information ensures right expectations and a good match

The financial sector plays an important role in the transition to a sustainable society. Clear and fair information about sustainability ensures that consumers and pension participants have the right expectations. This enables them to choose companies and products that match their preferences.
Consumers also find specific and well-substantiated claims more credible.

Market participants use the guidelines, but claims still need improvement

The AFM conducted an exploratory study on sustainability claims by twenty banks, insurers, investment firms and pension providers. We studies how these claims relate to the principles of the the Guidelines on Sustainability Claims. The AFM notes that financial market participants use the guidelines. But we also note that marketing language clashes with clear and specific explanations, and substantiation is often difficult to find.

Claims such as "We think a sustainable world is important" or "Our investments pay attention to society" are not specific. Such wording is vague and does not give a clear representation of the actual efforts or results. At the same time, these expressions raise expectations in the reader, leading to a high risk of mismatch. With regard to the ease of finding the substantiation, we have seen cases where substantiation is not available at all. In other cases it is located nowhere near the claim in a place which is difficult to find. We have also seen good practices during our exploratory study.

Work on these 4 key areas for improvement for sustainability claims

Our study shows four key areas for improvement for market participants. In our third ESG update (download below) we describe the four key areas for improvement, providing additional clarification as well as good and bad examples per area for improvement. We also describe the key takeaways from our exploratory study. These are the 4 key areas for improvement:
1. Ensure that sustainability claims are factually accurate and representative.
2. Specify what a sustainability claim means for the market participant or the product.
3. Ensure that substantiation is easy to find.
4. Provide necessary explanations for claims on climate neutrality, ESG ratings and impact.

Text continues below

2026: extra attention on sustainability claims in supervision

The investigated market participants indicated that they would use our areas for improvement and re-examine their claims. Some of the investigated participants have also adjusted their claims.

We expect market participants to further improve their claims where necessary. Sustainability in the financial sector is a strategic priority of the AFM. In 2026, the AFM will conduct another study into sustainability claims. We expect all claims to be correct, clear and not misleading (or balanced). The principles of the Guidelines on Sustainability Claims and this ESG update provide support for the sector.

More information

Fair sustainability claims: what does the AFM expect from you? (pdf, 807 kB)