On 4 October 2023, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published a Guideline on Sustainability Claims (the Guideline). A draft version of the Guideline was published for public consultation earlier this year. Please find an overview of the draft version of the Guideline in our previous blog.

The Guideline provides guidance on how financial undertakings can comply with sustainability disclosure standards. The Guideline sets out three overarching principles:

  1. Sustainability claims must be accurate, representative and up-to-date.
  1. Sustainability claims must be specific and substantiated.
  1. Sustainability claims must be understandable, appropriate and easy to find.

Further to the version that was published for consultation, the final version includes two additional ‘good practices’:

  1. A representative picture of sustainable impact. A market party makes the claim that it pursues a sustainable impact (1) through its investment policy and (2) through its sustainable business operations, such as solar panels on the roof and recycling company waste. When making this claim, the market party makes clear that its investment activity has a much greater sustainability impact than its business operations. This allows readers to get a clear picture of the relative impact of the market parties’ effort on sustainability factors.
  1. Concrete insight into sustainable investments. A market party claims on its website that it invests part of its assets responsibly. In making this claim, it specifically describes how much of the invested assets contributes to sustainable objectives, both in absolute figures as well as in relation to the market party’s total invested assets, indicating how much of it was invested per specified sustainable development goal. An interactive website with visual aids informs readers about the significance of those sustainable goals. Readers can get a clear picture of the extent to which the market party is investing responsibly and pursing sustainable goals. The use of an interactive webpage and visual aids promotes overview and accessibility for the reader.

The final Guideline, together with a feedback statement is available here (Dutch only).