New EU transparency and conduct of business regulations have placed the Dutch Authority for the Financial Markets (AFM) in the position of a supervisor rather than a regulator. While sustainability was not a core part of AFM’s strategy at the onset of the 2020s, it has become one of its priorities, especially due to rising investor demand in a country that is exposed to unique climate risks and hosts a strong financial sector. As AFM built its capacity, its early focus has been on surveying market trends and providing guidance to the market, particularly due to the implementation challenges entailed by SFDR and the CSRD. The AFM has also sought to support the development of EU regulation, often jointly with the French regulator. Increasingly, the AFM is turning towards enforcement, notably to prevent greenwashing and risk management, as physical and transition risks become more evident. Still, the AFM’s cautious approach to sustainable finance contrasts highly with the pioneering role of the Dutch Central Bank, De Nederlandsche Bank, its counterpart in prudential regulation.

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Sustainable Finance in the Netherlands

  • Dirk Schoenmaker,
  • Nathan de Arriba-Sellier

摘要

New EU transparency and conduct of business regulations have placed the Dutch Authority for the Financial Markets (AFM) in the position of a supervisor rather than a regulator. While sustainability was not a core part of AFM’s strategy at the onset of the 2020s, it has become one of its priorities, especially due to rising investor demand in a country that is exposed to unique climate risks and hosts a strong financial sector. As AFM built its capacity, its early focus has been on surveying market trends and providing guidance to the market, particularly due to the implementation challenges entailed by SFDR and the CSRD. The AFM has also sought to support the development of EU regulation, often jointly with the French regulator. Increasingly, the AFM is turning towards enforcement, notably to prevent greenwashing and risk management, as physical and transition risks become more evident. Still, the AFM’s cautious approach to sustainable finance contrasts highly with the pioneering role of the Dutch Central Bank, De Nederlandsche Bank, its counterpart in prudential regulation.