The Dutch financial regulator will prioritise its anti-greenwashing efforts in 2026, after finding insufficient claims from pension funds and other financial institutions.
AFM published an “exploratory study” of 43 sustainability claims made by 20 banks, insurers, investment firms and pension providers in the country across 2024 and 2025.
It assessed how the claims stacked up against its Guidelines on Sustainability Claims.
“Many sustainability claims are not sufficiently specific, giving rise to a mismatch risk,” the watchdog concluded.
It told investors they must explain what a claim means for a market participant, and provide “all the information needed to understand” it.
“If a claim cannot be substantiated, do not make the claim,” it warned.
AMF highlighted examples of bad practice, including investors that say they consider biodiversity in their decisions, and then point to a lengthy sustainability report “only four pages of which deal with biodiversity”; or those that rely too heavily on ‘Frequently Asked Questions’ or ‘More information’ buttons to provide meaningful information to members or customers on their websites.
It also criticised those that pledge “never” to invest in something when in reality they have a 5% revenue threshold for excluding such activities; and those that tout their commitment to be ‘climate-neutral’ before 2025, but give no specific year or strategy.
“In the coming year, we will pay extra attention to ensuring that sustainability claims are fair,” said the update.
“We expect market participants to further improve their sustainability claims where necessary.”
A spokesperson for AMF told IPE that its findings “apply to all sectors equally” and that “no sectors stood out positively or negatively in the study”.
“We observed that pension providers make a different kind of sustainability claims,” she added, referring to the tendency to focus on entity-level activities, rather than products.
“These claims must also comply with the legal requirement that information provided by the pension administrator must be correct, clear and balanced.
The four key areas for improvement, therefore, apply to this sector as well,” said the spokesperson.
Among its examples of ‘unbalanced’ claims, the AFM pointed to investors that showcase their allocation to sustainable assets without explaining what proportion of their entire portfolio that represents.
The supervisor said it had held discussions with all the companies it investigated, and that those that “proved to be incorrect and constituted a violation” of its code had been adjusted.









