The Dutch Authority for the Financial Markets has published a market overview on how a group of large Dutch banks and insurers are reporting climate transition plans and financed emissions for the first time in line with new sustainability reporting rules. The report outlines early progress but points to the need for more standardised, comparable disclosures and flags persistent data-quality constraints across the value chain. The AFM reviewed eight institutions that voluntarily published Corporate Sustainability Reporting Directive (CSRD) sustainability reports for 2024, ahead of the directive’s implementation in Dutch law, and found all of them included a transition plan. Among the four banks assessed, financed emissions from corporate lending were the most relevant source and reporting on transition plans and interim targets was detailed but varied significantly in scope and depth; the AFM highlights inconsistent definitions, measurement methods and units as a barrier to clarity and comparability. Among the four insurers assessed, emissions by asset class were presented in broadly similar ways but with differing levels of detail; most financed emissions stemmed from corporate and sovereign bonds, while transition plans focused mainly on financed emissions from proprietary investments, with comparability limited by differences in scope, units and formats and related sustainability information often disclosed outside the annual report. Across institutions, limited availability of reliable, up-to-date data deeper in the value chain drives reliance on estimates, models and external data providers. The AFM characterises CSRD sustainability reporting as a learning process for firms and stakeholders and encourages the sector to build on existing national and international industry initiatives to further standardise transition plan reporting.
Dutch Authority for the Financial Markets 2025-12-03
Dutch Authority for the Financial Markets publishes market scan on climate transition plan and financed emissions reporting by major banks and insurers
The Dutch Authority for the Financial Markets released a market overview on initial climate transition plans and financed emissions reporting by large Dutch banks and insurers under new sustainability rules. The report highlights early progress but emphasizes the need for standardized, comparable disclosures and identifies data-quality constraints. The AFM reviewed eight institutions' voluntary Corporate Sustainability Reporting Directive reports, noting varied scope and depth in transition plans and inconsistent definitions and measurement methods as barriers to clarity.