November 25, 2025
AFM – Netherlands Authorities for the Financial Markets – recently published its supervision report, reviewing Annual Reports of 30 (NL-based) stock-listed companies that fall under the “first wave” of CSRD scope.
The objective was to assess ESRS compliance, DMA outcomes, and transparency in interaction between DMA outcome and strategy and business model.
The report highlights good practices and pointers to improve sustainability reporting in coming years. It highlights three strategic focus areas
- Materiality assessment: companies have elaborate disclosure on the process and outcomes of the Double Materiality assessment, allowing stakeholders, including investors, to understand the context
- Justify exclusion / inclusion of sustainability topics: DMA is still not scientific, and often based on discretion and judgement. Providing a clear explanation of the material (and non-material) matters will allow readers to understand companies reporting choices.
- Most important is to disclosure the resilience of companies’ strategy and business model to the material impacts, risks and opportunities.
AFM will further engage with companies to share their detailed findings.