The regulatory and voluntary disclosure frameworks are fragmented. Dutch financial institutions are subject to a mix of regulatory, supervisory and voluntary frameworks, including the Corporate Sustainability Reporting Directive (CSRD), the Sustainable Finance Disclosure Regulation (SFDR), European Banking Authority (EBA) Pillar 3 disclosures, the European Central Bank (ECB) Guide on climate-related and environmental risks, Solvency II and reporting practices based on the Partnership for Carbon Accounting Financials (PCAF). These frameworks differ in scope, objective and required metrics, limiting cross-sector comparability. As a result, it remains uncertain whether the information currently disclosed is sufficient for assessing the risks attached to net-zero commitments from a prudential perspective.
Public disclosures remain uneven, with bank loan-book reporting currently offering the most decision-useful information. The report reviews disclosures by banks, pension funds and insurers in the Netherlands and other European jurisdictions. Large banks generally provide the most granular information, including sector-level pathway-alignment metrics, financed emissions and exposure data through EBA Pillar 3 templates. By contrast, pension funds and insurers generally rely on portfolio-level indicators such as financed emissions, weighted average carbon intensity (WACI), and fossil-fuel exposure, which are useful for high-level screening but do not allow robust assessment of alignment with sector-specific net-zero pathways. In a European comparison, Dutch financial corporates provide relatively more climate-related information and are more often subject to external assurance.
Due to their compatibility with sectoral alignment pathways, physical emissions-intensity metrics are more suitable than WACI for assessing alignment with net-zero commitments. Sector-level physical metrics, such as kgCO₂/m² in real estate or gCO₂/tonne kilometre in transport, can be compared directly against science-based net-zero pathways and therefore provide the clearest basis for assessing net zero-related prudential risks. WACI remains useful as a relative indicator of portfolio carbon intensity, but it has important limitations: as it is portfolio-weighted and cannot be benchmarked directly against physical pathways, the WACI cannot help to assess net-zero alignment. For instance, the WACI may move because of valuation, inflation or exchange-rate effects rather than genuine decarbonisation.
Internal supervisory data can partly address these limitations but not fully resolve them. DNB receives granular data on holdings and exposures for pension funds and insurers and can combine these with emissions estimates to construct institution-level and sector-level indicators, including financed emissions and decomposed WACI. Such data improve comparability and allow supervisors to analyse sector exposures beyond what public reporting currently permits. However, these approaches still depend on the quality of underlying emissions and activity data, and they do not eliminate the need for stronger sector‑level reporting where material risks are concerned.
