Loyens & Loeff

Experts

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Chloé Terrapon
Partner
Loyens & Loeff
Johanna Hädinger
Associate
Loyens & Loeff
Marit Bosselaar
Partner - Attorney at Law
Loyens & Loeff
Robin Moser
Partner
Loyens & Loeff
Sjoerd Pennink
Attorney at Law
Loyens & Loeff
Contributions by Loyens & Loeff Experts

1

ESG in the Netherlands
ESG in the Netherlands
Practice Notes

Executive narrativeIn practice, the environmental, social and governance (ESG) framework applicable in the Netherlands largely consists of EU rules applied in a market characterised by civil litigation and regulatory oversight.Supervisory authoritiesIn addition, the Dutch authorities pursue two pragmatic enforcement tracks:•consumer and competition-law are supervised by the Netherlands Authority for Consumers and Markets (ACM). This includes oversight of sustainability claims, commercial practices and sustainability-related agreements. On greenwashing, the ACM has positioned its Sustainability Claims Guidelines as the baseline ‘language of proof’ for commercial practices (such as marketing, websites and labels) and it expects substantiation that is specific, current, and verifiable•the financial sector is supervised by the Dutch Authority for the Financial Markets (AFM) focused on, among other things, ESG information in financial products, prospectuses and reporting. In its 2025/6 strategy, AFM made sustainability claims a supervisory priority for financial market participants and has published sector-specific expectations and review findingsGreenwashingThese two Dutch authorities lead to a dual-track claims

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