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Sustainability claims

The financial sector has a crucial role in making the economy more sustainable. Communications, including marketing, by market participants often contain sustainability ambitions and other sustainability claims. Existing standards for information provision apply to this. On this page, the AFM provides tools which aid market participants in complying with the standards for information provision.


To whom does the Guidance on sustainability claims apply?

Financial institutions and pension providers making sustainability claims

What does the AFM expect from market participants?

All sustainability claims made by market participants are correct, clear and not misleading, or, in the case of pensions, balanced. Market participants only make sustainability-related claims that are correct, clear and non-misleading, or, in the case of pensions, balanced.

Guidelines on sustainability claims and ESG update

The Guidelines on sustainability claims contain the three main principles for making fair and correct claims that meet information disclosure standards. Make sure claims are specific and can be substantiated in a way that is understandable and easy to find. If a claim cannot be substantiated, do not make the claim. Below you will find the 3 main principles visualized.


Four key areas for improvement

An exploratory study by the AFM shows that market participants are using the guidelines. But we also note that marketing language clashes with clear and specific explanations, and substantiation is often difficult to find. To assist market participants, the AFM shares four key areas for improvement:

  • Ensure that sustainability claims are factually accurate and representative.
  • Specify what a sustainability claim means for the market participant or the product.
  • Ensure that substantiation is easy to find.
  • Provide necessary explanations for claims on climate neutrality, ESG ratings and impact.
In our third ESG update we describe the four key areas for improvement, providing additional clarification as well as good and bad examples per area for improvement.

European Guidance

ESMA has identified four principles which aid investment firms in ensuring sustainability claims are clear, fair and not misleading. Building on four principles, the first note focuses on ESG credentials. The second note focuses on ESG strategies.

EIOPA has also identified four principles which aid insurers and pension providers in ensuring sustainability claims are clear, fair and not misleading. This publication elaborates on how to apply these principles.

EBA has published four general principles in her final report on greenwashing (p 39).


How to make a fair sustainability claim