The Role of Capital Market Service Providers in Corporate Governance

3. Case study: Belgium

Abstract

This case study chapter examines Belgium’s corporate governance framework in relation to Principle III.D. of the G20/OECD Principles, which calls for proxy advisors, ESG rating and data providers, and index providers to disclose and minimise conflicts of interest and ensure transparency in their methodologies. The chapter reviews how these service providers are regulated and monitored in Belgium and in the EU as well as prevailing market practices. The chapter concludes by identifying policy considerations for each type of service provider that could further strengthen the regulatory framework.

3.1. Introduction

Belgium’s capital markets are integrated into the broader European financial system. While relatively small compared to larger EU economies, they play an important role in financing domestic companies. Equity trading is centred on Euronext Brussels, which hosts 97 issuers and has a market capitalisation of USD 328 billion as of end of 2024 (OECD, 2025[1]).

The corporate landscape in Belgium is composed of several family-controlled publicly traded companies, with 59% of companies in which the 3 largest shareholders own the majority of the shares. The ownership share of institutional investors is 41%, in line with the global trend and the average amongst European member states (38%) (OECD, 2025[1]).

Belgium’s FSMA is the country’s conduct and financial markets and products supervisor since 2011, succeeding the former Banking, Financial and Insurance Commission (CBFA). It is an autonomous public institution whose governing-body members are appointed for a six-year term. FSMA plays distinct supervisory roles for certain market service providers, while for others ESMA – of which FSMA is a member – has either full or joint supervisory responsibilities.

In Belgium, the role of market service providers such as proxy advisors, ESG rating agencies and index providers is largely shaped by EU-level regulation and market practice. Belgian companies and investors primarily interact with global proxy advisors, as well as ESG rating agencies. Index providers have a stronger domestic presence through Euronext Brussels, which manages the BEL 20, the country’s flagship equity benchmark, and the BEL ESG index launched in 2023.

3.2. Regulation and monitoring of proxy advisors

3.2.1. Institutional framework for proxy advisors

Proxy advisors operating from or through an establishment in Belgium are subject to the EU Shareholder Rights Directive II (Directive (EU) 2017/828 (SRD II)-based framework of the Code of Companies and Associations. The FSMA has not been identified as the National Competent Authority (NCA) in charge of monitoring and supervising the transposition of Article 3j of SRD II (See Table 5, Annex VII, (ESMA; EBA, 2023[2]). Therefore, the Belgian regulator does not have an active role in monitoring compliance with provisions applicable to proxy advisors. This is without prejudice to the role of competent courts and tribunals in the enforcement of the Code of Companies and Associations.

ESMA does not currently have a monitoring role for proxy advisors in EU member states either, and its role and responsibilities are limited to the co-operation among NCAs and ESMA, which formally occurs within the ESMA Corporate Governance Task Force, a sub-group of the ESMA Issuer Standing Committee, composed of national authorities. This Task Force contributed to the 2023 ESMA-EBA Report on the implementation of SRD II (ESMA; EBA, 2023[2]).

3.2.2. Legal and regulatory framework for proxy advisors

The SRD II introduced a dedicated regime for proxy advisors, requiring greater transparency over their methodologies and management of conflicts of interest. Belgium transposed the SRD II through Law on April 2020 by inserting new sections into the Belgian Code of Companies and Associations. The transposition is closely aligned to the SRD II and includes a definition of proxy advisor and the key components of (i) transparency on research and methodology; (ii) management of conflicts of interest and (iii) disclosure of a code of conduct.

Belgian law requires proxy advisors to publish the code of conduct they apply and explain any non‑application or deviations, in line with Article 3j of SRD II. They must also provide annual, detailed disclosures on how they prepare their research, advice and voting recommendations, including their methodologies, key information sources, quality-control procedures and staff qualifications. In addition, proxy advisors must disclose the essential features of their voting policies for each market and explain how they take into account national legal, regulatory and market contexts, as well as company-specific circumstances. They are further required to indicate whether they engage in dialogue with companies or stakeholders and describe the scope of such interactions. They must also publish their policies for preventing and managing potential conflicts of interest.

The abovementioned obligations are disclosure-based: proxy advisors must make the required information available to the public free of charge on their websites for at least three years after the date of publication. As such, proxy advisors do not have an express duty to, for example, engage with companies or take local legal and market characteristics into account, but they must disclose this information when they do.

Under SRD II and the Belgian framework, the requirement for proxy advisors to apply and disclose a code of conduct is generally met by adherence to the industry Best Practice Principles for Shareholder Voting Research Providers (Best Practice Principles) (Box 3.1).

On conflicts of interest, the framework goes beyond mere adherence to a code of conduct or a comply‑or‑explain approach. Proxy advisors have a mandatory duty to identify and promptly disclose to their clients any actual or potential conflicts of interest and any business relationships that could reasonably influence their analysis or voting recommendations.

The Belgian Corporate Governance Code of 2020 also includes a recommendation that relates to proxy advisors. Principle 8.8 in the section on institutional investors states that “The company should discuss with institutional investors the implementation of their policy on the exercise of institutional investors’ voting rights in the relevant financial year and ask institutional investors and their voting agencies for explanations on their voting behaviour” (Belgium Corporate Governance Committee, 2020[3]). Market participants consider this recommendation and how it describes the role of proxy advisors, defined as “voting agencies”, unbalanced. While the recommendation aims to encourage dialogue between companies and their shareholders, it could more explicitly acknowledge the role of proxy advisors as service providers that assist institutional investors in exercising their voting rights. Doing so would help ensure that investors’ stewardship policies are properly understood. A review of the Belgian Corporate Governance Code of 2020 is under consideration and may provide an opportunity to clarify the recommendation on institutional investors and the role of proxy advisors.

3.2.3. Best Practice Principles for Shareholder Voting Research Providers

The Best Practice Principles for Shareholder Voting Research Providers (Best Practice Principles) were developed in the context of the EU’s efforts to encourage transparency, research quality and conflicts of interest management of proxy advisors (Box 3.1). Given the cross-border operations of major proxy advisors, the Best Practice Principles can serve as a useful point of orientation for market practice. Market participants broadly acknowledged that proxy advisors have become more transparent, owing in part to the Best Practice Principles.

Box 3.1. The Best Practice Principles for Shareholder Voting Research Providers

Best Practice Principles Group

Following ESMA’s 2012 public consultation on the proxy advisory industry (ESMA, 2012[4]) and considering the different business models of proxy advisors, ESMA opted to encourage the proxy advisor’s industry to adopt a principles-based code of conduct. This led to the establishment in 2013 of the Best Practice Principles Group (BPPG), a private sector-led body that developed the Best Practice Principles for Shareholder Voting Research Providers (Best Practice Principles) in 2014. The Best Practice Principles set out commitments related to transparency, conflicts of interest and quality of research. The Best Practice Principles were updated in 2019, following an earlier follow-up review by ESMA (ESMA, 2015[5]).

The Best Practice Principles operate on an apply-and-explain basis. They are intended to complement law and stewardship codes within broader regulatory frameworks. Each signatory publishes and annually updates a public statement of compliance on its own website and via the BPPG website. The major proxy advisory firms regularly publish their compliance statements (BPPG, 2025[6]).

Best Practice Principles

The three core Best Practice Principles are (BPPG, 2019[7]):

1. service quality: public disclosure of methodologies, sources, quality controls, staff expertise, and how market and issuer-specific contexts are considered

2. conflicts of interest avoidance or management: a public conflict of interest policy and case‑by‑case disclosure and mitigation of actual or potential conflicts

3. communications policy: clear policies for communication with issuers, shareholder proponents and other stakeholders while prioritising accountability to investor clients.

Best Practice Principles Oversight Committee

To provide independent oversight, the Best Practice Principles Oversight Committee (BPPOC) was set up in 2019, bringing together representatives from across the investment chain, academia and governance experts. The BPPOC features an independent chair, six institutional investor representatives and two listed company representatives. The BPPOC’s terms of reference emphasise independence from signatories, authority to refine its own procedures, monitoring of individual signatory compliance via their public statements and publication of an annual report.

The BPPOC’s purpose is to monitor and report on the implementation of the Best Practice Principles by signatories, assess their compliance annually through public statements and reviews, and facilitate dialogue between proxy advisors, investors and issuers. The process involves confidential feedback from the BPPOC to proxy advisors on their annual compliance statements. In its 2024 Annual Report, the BPPOC found that all signatories continued to be compliant with all three Best Practice Principles, with improved practices by signatories (BPPOC, 2024[8]).

In 2025, the BPPOC adopted an enforcement protocol outlining the procedural steps in case of signatories’ non-compliance with the Best Practice Principles (BPPOC, 2025, pp. 43-45[9]).

Complaints procedure

The BPPG provides for a complaint’s procedure related to the application of the Best Practice Principles. The procedure establishes that complaints should be first filed with the relevant signatory, within six months of the alleged material non-compliance. If the signatory does not respond within 30 days, or its response fails to comply in all material respects with the Best Practice Principles, the complainant may escalate to the BPPG. Upon escalation, the BPPG will acknowledge receipt within five working days, investigate and aim to report an outcome within 25 working days of acknowledgement. BPPG’s complaints procedure has been used only once in 2022 since its establishment (BPPOC, 2024[8]; 2025[9]).

Source: BPPG website.

The Best Practice Principles broadly reflect SRD II’s objectives of promoting transparency, reliability and effective conflict management, but go further by recommending a communications policy that sets clear expectations for engagement with issuers, shareholder proponents and other stakeholders while maintaining accountability to investor clients. This aspect is not specifically addressed in SRD II but is frequently highlighted by stakeholders as a practical priority.

3.2.4. No formal registration of proxy advisors and SRD II review

There is no registration requirement or list of proxy advisors operating in Belgium, as in nearly all EU member states. Further to the 2023 ESMA-EBA report and the envisioned review of the SRD II, there is an ongoing debate on introducing an EU-level basic registration or notification regime for proxy advisors.

As the EC considers whether to review SRD II by late 2026, taking into account recent assessments of the framework applicable to proxy advisors, options are being explored to enhance transparency and supervisory clarity (ESMA; EBA, 2023[2]) (Centre for Strategy & Evaluation Services, 2025[10]). ESMA suggested an EU-level registration or notification mechanism, accompanied by a public list of proxy advisors operating in the EU (including an indication of whether they apply a code of conduct), and has discussed potential adjustments to supervisory responsibilities, with an enhanced role for ESMA. ESMA also emphasised that any changes should be proportionate and avoid deterring new entrants in an already concentrated market or encourage relocation outside the EU.

3.3. Market practices of proxy advisors, institutional investors and listed companies

3.3.1. Market structure and context for proxy advisors in Belgium

The European and Belgian market of proxy advisors is concentrated. In the Belgian market, international proxy advisors are the dominant actors and there are no Belgian proxy advisory firms. Belgian companies generally suggest that institutional investors base their voting decisions on proxy advisors’ recommendations.

There is no established investor community organisation in the Belgian market. Market participants recognise that corporate governance issues remain focused on disclosure, reflecting limited institutional investor pressure and the prevalence of family-controlled companies.

3.3.2. Conflicts of interest and methodology transparency from proxy advisors

Companies and investor clients generally find proxy advisors’ policies clear and acknowledge improved disclosure in recent years.

Stakeholders described an overall positive picture of proxy advisors’ transparency of voting benchmarks and methodologies, although reporting on how they take local market and regulatory conditions into account remains weaker. For example, some proxy advisory firms are perceived to adopt an overly strict approach by treating the comply or explain recommendations of the Belgian Corporate Governance Code as if they were binding rules. More broadly, methodologies are sometimes viewed as rigid and insufficiently tailored to local governance nuances and tax treatment of different types of executive compensation, leaving limited scope for company-specific justification or proportionality.

As most proxy advisors base their analyses and voting recommendations on publicly available information, late or insufficient corporate disclosure tends to translate directly into their voting recommendations. Proxy advisors’ reports with voting recommendations do set out the relevant legal and regulatory background, although they do not explicitly flag this as the basis for their recommendations. Proxy advisors also reported they tend to build in transition periods for companies to adapt to major policy changes, such as those on gender diversity or multiple voting rights, before revising their voting recommendations.

There is limited evidence or perception of conflicts of interest in proxy advisors by Belgian market participants. Proxy advisors adopt separate commercial and research functions through organisational firewalls.

3.3.3. Review of benchmark policies and engagement of proxy advisors with listed companies

Overall, Belgian companies report increasingly constructive interactions with proxy advisors but note that engagement processes vary significantly depending on each proxy advisory firm. Consistent with the ESMA-EBA (2023[2]) report findings, Belgian companies note that when company feedback is permitted, the review windows are often too short and their input is not always reflected or accompanied by an explanation of how it was considered. Companies also highlight how these practices have a disproportionate impact on smaller companies, which may lack the resources to respond within tight review timelines.

In Belgium, one proxy advisor noted it shares its voting research report with the covered company only upon request, offering a 24-hour window for review and feedback. Once companies receive the draft report, they may correct factual errors at no cost and, in limited cases, submit additional information. Another proxy advisor runs a more formal, fee-based process via a digital platform with no in-person interactions: only companies that pay receive a draft report and can fact-check it within a 24-hour window of time, and any comments on the final report can be submitted through the platform to be then appended to the analysis. This proxy advisor does not change the report based on the feedback. These divergent models – request-driven versus pay-to-access – underscore the variability companies face.

Belgian companies value opportunities to engage with proxy advisors and appreciate having a designated case handler to convey corrections. Some companies also retain specialist firms to manage their relationships with proxy advisors. Further, while some companies are prepared to review and correct materials within 24-hour windows, they would welcome longer review periods and clearer explanations of how their input is considered. This aligns with the BPPOC’s 2024 call for stronger disclosure on issuer‑feedback processes, which calls signatories to clearly specify the extent to which issuers can verify, review or comment on information used in research reports and, under Best Practice Principle 3, to explain whether and how issuers have a mechanism to review reports or data prior to publication (BPPOC, 2024[8]).

Complaints mechanisms

Proxy advisors report only isolated cases of complaints despite having dedicated channels, and the BPPG has recorded only one complaint case since its establishment. Proxy advisors tend to interpret this as evidence that companies and clients are satisfied with their services and voting recommendations. Companies, however, point to limited familiarity with the complaint procedures, and given the high concentration in the market of proxy advisors, some consider that the absence of more complaints may reflect fears of negative consequences.

3.4. Regulation and monitoring of ESG rating and data providers

In Belgium, the regulatory framework for ESG rating providers is provided by the EU ESG Rating Regulation 2024/2005, and there are no specific regulations or recommendations that are Belgium-specific. The regulation does not include ESG data providers, which are therefore not subject to regulation in Belgium. FSMA has, however, identified a list of good practices tailored to ESG data providers on its website (FSMA, 2025[11]).

3.4.1. Institutional framework for ESG rating providers

ESMA assumes a supervisory role for ESG rating providers that mirrors its responsibilities for CRAs and includes the ability to request information, conduct investigations and on-site inspections, as well as impose fines and supervisory measures. While ESMA’s oversight is extensive, the EU ESG Ratings Regulation makes clear that neither ESMA, the EC nor member states may interfere with the methodologies applied by ESG rating providers. To fund its supervisory activities, ESMA will levy fees on providers proportionate to their annual turnover.

In Belgium, FSMA does not have the mandate to monitor or supervise ESG rating providers under the ESG Ratings Regulation. Instead, the framework envisages ESMA’s co-operating with NCAs, mirroring the model used for CRAs: ESMA may request support from NCAs, for example to assist with information requests or on‑site inspections, to ensure effective oversight in each jurisdiction.

3.4.2. The EU ESG Ratings Regulation

The EU ESG Rating Regulation was published in December 2024 and entered into force in all EU member states in January 2025. The ESG Rating Regulation will apply from July 2026 onwards. Member states must designate an NCA by April 2026. ESG rating providers operating in the EU will require authorisation from ESMA, which is entrusted with ongoing supervision and enforcement powers. ESMA will publish information on authorised ESG rating providers through its website and via the European Single Access Point (ESAP).

Under the EU ESG Rating Regulation, “ESG rating provider” is defined as “a legal person whose activities include the issuance, and the publication or distribution, of ESG ratings on a professional basis” (EU, 2024, p. 12[12]). The regulation applies to any legal person that wishes to operate as an ESG rating provider in the EU and does not include ESG data providers.

For ESG rating providers established outside the EU that may offer their services in the EU, the regulation establishes three regimes: equivalence, endorsement and recognition. Equivalence is when the EC assesses a third-country ESG rating framework as equivalent, allowing non-EU providers’ ratings to be offered in the EU. Endorsement is when a third-country ESG rating group sets up an EU‑authorised entity that formally approves the group’s ratings developed outside the EU and ensures they meet EU-equivalent requirements. Recognition is when ESMA permits a third-country ESG rating provider that meets specific small-provider criteria to offer ratings in the EU, provided it appoints an EU‑based legal representative accountable to ESMA and meets other organisational requirements.

The EU ESG Ratings Regulation aims to tailor the level of regulatory oversight to the size of the ESG rating provider, at least for a time-limited period following its application. It establishes a temporary regime of up to three years, designed to facilitate their market entry and support their development. Smaller providers are required to register but are subject only to selected obligations, primarily concerning governance and transparency. In addition, ESMA may, at its discretion and upon request, grant exemptions from certain requirements, such as annual methodology reviews or the establishment of an oversight function.

The EU ESG Rating Regulation imposes governance requirements to ensure the integrity and reliability of ESG rating providers’ activities, alongside safeguards to minimise conflicts of interest and ensure transparency of methodologies. The regulation also reinforces engagement and accountability towards rated issuers. ESG rating providers must comply with the following requirements as explained below.

Governance

Providers are expected to ensure the independence of their rating activities and conduct internal due diligence to support this. They should adopt policies and procedures that ensure ESG ratings are based on solid analysis and relevant information. Providers must also establish an oversight function with adequate resources. They are required to review their rating methodologies at least once a year, although an independent or external review is not required.

Methodologies disclosure

Providers are expected to publish their methodologies, models and key assumptions on their websites. They must ensure that their fees are fair, reasonable, transparent and non-discriminatory. They are required to provide separate ratings for environmental, social and governance components rather than a single aggregated ESG score.

Staff requirements

Providers must ensure that analysts, employees, contractors and other staff involved in issuing ESG ratings have the necessary skills, competence, independence and integrity. They must also apply a nine-month cooling-off period before any staff member or senior manager can join the management of a rated entity.

Conflicts of interest

Providers must refrain from offering certain services, including consulting, unless strict safeguards are in place to ensure independence. They must also prevent staff involved in ratings from engaging in activities that create conflicts of interest. They are required to disclose to ESMA all actual or potential conflicts, including those arising from ownership or control.

Engagement with issuers and complaints

Providers must give issuers at least two full working days’ notice before issuing a first rating and, upon request, share the underlying data free of charge. They must also establish procedures to receive and address complaints.

Implementation of the EU ESG Ratings Regulation is underway. ESMA has established a dedicated task force and is recruiting technical staff to prepare for full application by July 2026. ESMA’s priorities are to (i) engage with market participants to understand key issues and questions around implementation, (ii) finalise Level II measures on how the regulation will be implemented, and (iii) define registration and supervisory processes. Supervision will follow a risk-based approach broadly consistent with the model used for CRAs.

As for Level II measures, ESMA developed Regulatory Technical Standards (RTS) that provide operational details for many of the ESG Rating Regulation provisions (ESMA, 2025[13]). The RTS address: (1) application details for authorisation, recognition or endorsement of EU and third-country ESG rating providers; (2) conflict-of-interest safeguards, such as required organisational and physical separation of activities; and (3) disclosure requirements, defining how methodologies, assumptions, limitations and organisational information should be transparently presented to the public and users.

3.4.3. Market participant views on the ESG Ratings Regulation

Issuers are broadly supportive of the EU’s initiative to regulate ESG rating providers, recognising the potential to strengthen trust and credibility in this growing and influential market. Market participants underline the importance of ensuring the framework remains proportionate and fully aligned with existing EU sustainability legislation. Feedback from issuers suggests that greater transparency, more balanced engagement and enhanced consistency across providers are welcome improvements.

ESG data providers are currently out of scope of the EU ESG Ratings Regulation, and several participants see scope for further clarification. The EU already expects to review the scope of the ESG Rating Regulation in four years and determine whether to extend it to ESG data providers as well.

While participants are supportive of the newly established framework, there are still pending questions about the limits of the EU ESG Ratings rules. In particular, uncertainties remain around what counts as an ESG rating as opposed to research, indicators or raw data, how the exclusion of non-profit, free-of-charge ratings should work in practice, and when a provider is considered to be operating in the EU. Clear examples and guidance from the EC or ESMA should help ensure the regime is applied consistently and proportionately while reducing opportunities for regulatory arbitrage.

Institutional investors also flagged the possibility of introducing a formal correction mechanism for ESG ratings, allowing issuers to contest factual inaccuracies through a dedicated and clear process. This reflects a common concern among market participants that current frameworks afford limited recourse when errors or misrepresentations are made in ESG assessments (NBIM, 2025[14]).

ESG ratings by asset managers and their marketing uses: SFDR obligations

Asset managers are not within the direct purview of the EU ESG Rating Regulation and are not considered as ESG rating providers when they produce assessments only for internal use or under a mandate for a single client. A separate rule applies for asset managers that include an ESG rating in their marketing materials: under the Sustainable Finance Disclosure Regulation (SFDR) 2019/2088, Article 13(3) (inserted by the EU ESG Rating Regulation) requires them to publish information about that rating on their website and to link to it in the marketing materials from July 2026 onwards.This approach aims to avoid regulation of already-authorised firms and supports proportionality and flexibility in how asset managers integrate ESG data.

Asset managers would not be subject to ESMA’s supervision under this exception. If asset managers disseminate “quasi-ratings” to clients without charging a fee for the ratings but benefiting from the higher interest of asset owners that use such ratings, an uneven playing field may arise.

This potential gap has also been flagged by stakeholders, for example, where asset managers publish ratings or ESG assessments without charging fees (or for a single client use), meaning they may fall outside the regime’s core requirements, raising level playing field questions. However, the EC has indicated that the regulatory perimeter could be revisited after implementation, considering market outcomes and an assessment of the regulation’s effectiveness.

3.4.4. Framework applicable to ESG data providers

The EU ESG Rating Regulation does not include ESG data providers. FSMA publishes guidance on its website, drawing on IOSCO recommendations (IOSCO, 2021[15]), where it provides clarifications on what is meant by ESG data and includes a list of good practices (FSMA, 2025[11]). In line with IOSCO’s recommendations (IOSCO, 2021[15]), FSMA calls users of ESG data to conduct structured due diligence on their providers and verify the transparency of their methodologies. FSMA also encourages users to scrutinise potential conflicts of interest, ensuring the provider has policies to identify, mitigate and disclose any actual or potential conflicts that could undermine independence or objectivity.

3.5. Market practices of ESG rating and data providers, institutional investors and listed companies

3.5.1. Market structure and context for ESG rating and data providers in Belgium

Belgium’s ecosystem is characterised by strong reliance on global ESG ratings and data providers alongside a smaller set of niche, sector-focused regional firms. There are no local ESG rating providers.

3.5.2. Conflicts of interest

Stakeholder feedback did not indicate conflict-of-interest issues in the Belgian market. However, some note that such concerns may have diminished as the market has consolidated, with larger providers better able to meet stricter regulatory expectations and implement stronger governance, such as clearer firewalls and the separation between commercial and analytical activities.

Several major ESG rating providers report a strict separation between commercial and analytical functions, with information walls that they say prevent revenue considerations from influencing their research outputs. Providers also report that they are strengthening their internal oversight arrangements ahead of the ESG Ratings Regulation application in July 2026, including clearer roles, documentation and escalation to methodology or oversight committees.

Firms noted that, in general, ESG ratings teams do not influence index composition decisions within the index division, helping to prevent potential conflicts across business lines. Providers also describe having peer-review processes between their methodology and analytical teams. Overall, these measures are intended to safeguard analytical independence and enhance accountability for underlying methodologies.

3.5.3. Methodology transparency and updates

ESG rating providers generally publish detailed methodologies, including models, assumptions, data sources and their limitations. Some ESG rating providers rely on questionnaires completed by rated issuers, while others use only publicly available information. While most ESG ratings draw on publicly available information, some also include non-public data.

Many providers operate a public consultation cycle for methodology updates, typically opening in November for market feedback from issuers, investors and non-governmental organisations (NGOs) with agreed changes implemented in Q1 of the following year. Material changes are generally subject to consultation, while minor or technical clarifications may be issued as notices. Several providers have an independent internal audit.

Market participants and Belgian issuers flagged that methodologies are often misaligned with sectoral or regional issues, leading, for example, to governance being over-weighted in sectors where environmental or social factors are more critical or vice versa. Issuers note that methodologies are generally well disclosed, but they are often unable to fully understand the weighting or scoring logic and the identification of improvement pathways.

ESG ratings are updated annually. There is, however, no fixed timetable for updating ESG ratings, and ESG rating providers typically do not indicate processes they use to determine when a specific rating will be revised.

Institutional investors reportedly rely on ESG rating reports, in some cases primarily for standardised underlying information rather than headline scores, a practice that may evolve as company disclosures expand under the EU Corporate Sustainability Reporting Directive.

Controversies

Controversies play a significant role in ESG ratings, but the threshold for inclusion often appears low, and an incident making headlines may be treated as a controversy. Raising the bar by requiring more well‑documented and timely cases could improve rating stability, enhance investor trust and better protect issuers from reputational harm due to minor or unverified incidents. Some ESG rating providers note they have dedicated staff and teams for controversy monitoring, which is based on media (e.g. news articles) and a process that involves engagement with issuers.

3.5.4. Belgian market participant views and engagement with ESG rating providers

Belgian market participants acknowledge that ESG ratings increasingly shape rated issuers’ reputation, capital market access and debt financing conditions, as well as investor perceptions and decisions.

Increasing engagement with ESG rating processes has helped some issuers strengthen their governance and sustainability-related internal controls, as major ESG rating providers’ platforms offer channels for interaction and data corrections. However, concerns remain as methodologies are perceived as opaque or not always aligned with sectoral or local contexts, and ratings for the same company can vary widely between different providers. Ratings can be distorted by data gaps or box-ticking methodologies, penalising firms that do not disclose certain practices or follow ratings less actively, regardless of their actual performance.

A common concern among Belgian market participants is that ESG rating providers impose significant resource demands, with multiple questionnaires and reporting cycles overlapping with regulatory requirements, which weigh on issuers’ resources. This results in many issuers focusing selectively on more prominent or more sector-relevant ESG rating providers.

Issuers note that engagement with ESG rating providers is not structured and does not occur frequently. It tends to focus on correcting factual errors rather than discussing methodologies. In these instances, issuers can occasionally supply non-public evidence (for example, a policy adopted by the company but not disclosed online) to ensure ratings’ accuracy. Public disclosure and proactive corrections of draft ESG rating reports could result in improvements in some ratings over time.

Not all ESG rating providers inform issuers they are being rated, but a two-day notice before the first rating is issued is now required in the EU ESG Rating Regulation. Some providers have free-access portals available to issuers. Some providers also publish detailed information of their procedures and avenues for engagement online.

In Belgium, ESG rating providers report that only about a quarter of issuers use dedicated channels. They generally comment on specific datapoints, but these do not trigger a rating review unless predefined thresholds are met. One provider allows issuers to log into a dedicated platform and add commentary to specific datapoints; these remarks are directly visible to clients but do not trigger a rating review.

Some issuers also note that commercial arrangements allow them to share ESG rating reports with investors. Institutional investors also note that ESG ratings are not updated with a predictable timeframe, but often only when issuers publish sustainability reports, leading to inconsistencies that can affect their best-in-class screening.

3.5.5. Belgian market participant views and engagement with ESG data providers

Belgian institutional investors report that common issues related to data providers include coverage gaps (for instance, delisted or uncategorised companies), bias towards large capitalisation with greater disclosure resources, and a reliance on generic criteria that can miss sector-specific risks. These constraints shape how investors read headline scores, prompting greater focus on underlying indicators and qualitative context.

Institutional investors note that they increasingly rely on multiple data and ESG data providers. This diversified approach supports their investment decisions where data coverage and methodologies vary. Some investors cross-check provider outputs against public sources and NGO disclosures, using external references to corroborate material data points and reduce risks. Two types of data were specifically mentioned where divergence between data providers is common: estimated greenhouse gas emissions and the identification of a company as selling controversial weapons. These data points are important to institutional investors in Belgium, as they must disclose the financed emissions in their portfolios by the SFDR and are prohibited by law from investing in companies that sell controversial weapons.1

Some investors explain that they integrate data into their own proprietary ESG models, applying in-house judgements to interpret rankings and scores, and document their assumptions. When gaps or inconsistencies arise across regions or sectors, investors apply adjustments; for example, reweighting indicators, substituting alternative sources or flagging holdings for enhanced due diligence.

3.6. Index providers in Belgium

Belgium’s equity index landscape is underpinned by Euronext Brussels, which is registered under the EU BMR as a benchmark administrator and manages the BEL indexes (notably BEL 20, BEL Mid, and BEL Small). Euronext Brussels administers a total of 43 benchmarks, of which the BEL 20 is the only significant benchmark according to the EU BMR (Euronext Brussels, 2024[16]). BEL indices provide local depth while large Belgian issuers also feature widely in global index providers, giving investors international comparability. In 2023, Euronext created BEL ESG, expanding the domestic toolkit for sustainability-related strategies. BEL ESG is a free-float market capitalisation weighted index that reflects the performance of the 20 issuers with the best ESG risk rating selected among the best in their subindustries from the BEL 20 Index and Bel Mid Index. The ESG ratings are provided by Sustainalytics. It excludes issuers involved in controversial activities, including but not limited to tobacco, controversial weapons, oil sands or assessed to be non-compliant with the UN Global Compact Principles.

Alongside these domestic benchmarks, broad coverage by major global index providers ensures Belgian issuers are visible to international capital and comparable across markets.

3.6.1. The EU Benchmarks Regulation

Background

The EU BMR, in force since 2018, was introduced in response to major benchmark manipulation scandals – such as those related to London Inter-Bank Offered Rate (Libor) in the United Kingdom – to ensure the integrity and reliability of benchmarks used in financial markets. It aims to protect investors and consumers through transparency and rigorous oversight of benchmark-setting.

Under the original framework, all EU benchmark administrators must be authorised or registered and comply with governance and data quality standards, with requirements proportionate to each benchmark’s economic importance. Benchmarks are categorised as critical, significant or non-significant based on their usage, with critical benchmarks (like key interbank interest rates) subject to the strictest rules. In 2019, the BMR was amended to introduce two categories of climate-focused benchmarks – the EU CTB and the EU PAB – and to require benchmark administrators to disclose how their methodologies reflect ESG factors.

2025–26 Reform: Risk-based scope and key changes

Regulators found that the regulation’s broad scope was not sufficiently proportionate, as even very small or niche benchmark providers had to comply fully from the moment any of their indices were used by EU firms.

To address these issues, the EU adopted an amendment to the BMR in 2025 (effective January 2026) that shifted to a more risk-based and proportionate scope of index providers’ regulation. Supervision shifts to a hybrid model. ESMA will supervise EU critical benchmarks and act as a gatekeeper for third-country benchmarks entering the EU. NCAs are tasked with overseeing national critical, significant (and other in‑scope) benchmarks provided by EU-based administrators.

• Narrowed scope: benchmarks deemed non-significant (the broad category of smaller benchmarks) are removed from the regulation’s scope. Only critical or significant benchmarks remain subject to BMR requirements, drastically reducing the number of benchmarks and administrators under supervision (roughly an 85–90% reduction in scope). EU administrators falling outside the scope may still opt in to BMR compliance voluntarily, subject to certain conditions, but are no longer obliged to comply by default.

• Focus on climate benchmarks: certain categories of high policy importance remain under the scope of BMR regardless of size. All EU CTBs and EU PABs remain in scope (treated as significant benchmarks), meaning any provider of such benchmarks, whether EU-based or not, must be authorised, registered or otherwise approved under the BMR to ensure proper oversight.

Overall, the reform introduces a more proportionate approach, relieving small benchmark providers while keeping strict safeguards for benchmarks that are systemically important or serve key policy objectives.

Transparency of methodologies

Under Article 13 of the BMR, benchmark administrators, whether ESG-focused or not, must develop, operate and administer their benchmarks and related methodologies transparently. In practice, this requires them to publish or make available the key elements of the methodology for each benchmark or benchmark family; to disclose the internal review and approval process for that methodology, including how often it is reviewed; and to set out the consultation procedures for any material methodology change. Administrators must explain how the methodology reflects ESG factors for each benchmark or benchmark family, except for interest-rate and foreign-exchange benchmarks.

For ESG-oriented benchmarks, the BMR imposes additional transparency obligations. When a benchmark references ESG factors, the administrator must explain how those factors are reflected in the methodology and include detailed ESG-related information in the benchmark statement.

Benchmark administrators are also required to periodically review and update their methodologies to ensure they remain robust, reliable and fit for purpose. ESMA’s guidelines, which were developed under the older framework and may need updating with the revised BMR rules, reinforce the regulation’s requirement that material changes must be consulted on, even under shortened timeframes, with adequate notice and clarity (ESMA, 2021[17]).

Conflicts of interest

Under the BMR, benchmark administrators are required to implement robust measures to identify, prevent and manage conflicts of interest that may arise, including with respect to their managers, employees or any affiliated parties and contributors or users of the benchmark. The BMR does not impose a specific obligation to publicly disclose the ownership structure of administrators. However, under the BMR’s delegated Regulations for authorisation (EU 2018/1646) and recognition (EU 2018/1645), applicants must submit ownership-structure information to the competent authority as part of their application, but the information is not publicly disclosed (EC, 2018[18]; EC, 2018[19]).

The provisions clarify that any judgement or discretion exercised in the benchmark determination process must be conducted independently. Administrators must establish and maintain effective policies, procedures, and organisational arrangements to safeguard the integrity and independence of benchmarks. These measures must be regularly reviewed and updated, taking into account the degree of discretion involved and the potential risks posed by the benchmark.

Supervision and oversight: ESMA and FSMA

Under the BMR applicable between 2022 and 2025, supervisory duties were shared between NCAs and ESMA. National regulators, including Belgium’s FSMA, supervised EU benchmark administrators based in their jurisdiction, including those administering critical benchmarks, whereas ESMA supervised and managed the transparency of authorised EU administrators and of recognised non‑EU benchmarks that could be used in the EU.

One of the most relevant interest-rate benchmarks globally is the Euro Interbank Offered Rate (Euribor), published by the European Money Market Institute (EMMI) as its administrator. The benchmark is calculated daily on transaction data contributed by panel banks. By early 2019, EMMI had reformed the Euribor methodology to reduce the reliance on expert judgement in its calculation, and in July 2019, FSMA granted EMMI authorisation as a benchmark administrator for Euribor.

The Euribor reform process was based on recommendations by the FSB Official Sector Steering Group (OSSG) and the Euro Risk-free Rate Working Group under the leadership of the European Central Bank. The FSMA actively participated to the work of both groups (in case of the OSSG, the Chairman of the FSMA contributed in his function as IOSCO Vice-Chair at the time). Under FSMA’s supervision, the Euribor college of supervisors was set up and the EURIBOR methodology was changed from expert judgement-based to a benchmark based to the fullest extent on transactions. Following a legislative amendment, the supervision of critical benchmarks (as well as of recognised third‑country benchmarks) was transferred to ESMA in January 2022. FSMA worked closely with ESMA to ensure a smooth transfer of its responsibilities and continues to sit on the Euribor college today.

Under the revised BMR framework, effective from January 2026, ESMA’s supervisory role has further expanded. ESMA continues to directly supervise all EU critical benchmark administrators and now also oversees any EU administrator that endorses a third-country benchmark. This change establishes ESMA as the single-entry point for all third-country benchmark administrators operating in the EU.

NCAs like FSMA retain responsibility for supervising significant benchmark administrators within their jurisdiction and for any national critical benchmarks. FSMA ensures that local administrators comply with BMR requirements and continues to play a collaborative role in EU-wide supervisory co-ordination. It maintains regular communication with other NCAs, including through working groups such as the one developed for the benchmarks provided by the Euronext group. This division of responsibilities aims to maintain robust oversight while improving regulatory coherence across the EU.

Authorisation and registration

Under the BMR, benchmark administrators – ESG and non-ESG – that are within scope are subject to registration or authorisation requirements. Administrators must be authorised if they provide significant or critical benchmarks, while smaller providers of non-significant benchmarks may register instead. Authorised and registered entities appear in ESMA’s public register, which specifies the benchmark types they may offer. The register also covers third-country administrators admitted via the BMR’s equivalence, recognition or endorsement regimes, enabling non-EU benchmarks to be used in the EU under defined conditions.

Euronext

Euronext’s index design operations are primarily conducted by teams based in Paris and Amsterdam, with final approval for indices like the BEL 20 made by Euronext Brussels. Euronext has an oversight committee composed of academics and investors, which plays a key role in decisions regarding index changes and the treatment of corporate events. Euronext can independently decide on index modifications without requiring pre-approval from regulatory bodies such as FSMA or ESMA.

Index data is available for purchase directly from Euronext or via commercial data providers. Euronext also engages with investors through occasional educational initiatives, such as webinars and ESG-focused events co-hosted with Sustainalytics, notably around the launch of the BEL ESG index. Euronext informs issuers of their inclusion in BEL ESG, but does not communicate on a regular basis or when a company is no longer included in the index.

3.6.2. Market participant views on index providers

Stakeholders acknowledge that index providers exert an indirect but strategic influence in Belgium, as inclusion in ESG indices can attract investor interest. These indices incentivise issuers to improve disclosures and reporting practices, often driving greater alignment with ESG criteria. However, index providers often rely on third-party ESG ratings and possible inaccuracies or inconsistencies in those ratings can be amplified.

A growing concern among institutional investors is the rising cost for licensing or using well-known indices to benchmark their portfolios. The escalating fees may place financial pressure, particularly on smaller asset managers. These challenges underscore the need for policy dialogue around data affordability and the potential for regulatory or industry-led solutions to ensure fair and equitable access to essential market information.

Issuers report not having specific engagements prior to inclusions into an index, and some mention having received only a notification upon inclusion. Issuers do not receive a notification when they are excluded from an index. This means there is no ongoing communication, feedback or consultation regarding methodology, data inputs or potential revisions to the index. This limited interaction suggests that index inclusion operates largely as a one-way process for the issuer, with minimal opportunities to clarify sector nuances or address data issues post-inclusion, which is especially important for ESG indices.

3.7. Policy considerations

Belgian listed companies view proxy advisors, ESG rating agencies, ESG data providers and index providers as influential external governance actors in corporate oversight. However, companies report several challenges in their interactions with these service providers, including opaque methodologies, rigid one-size-fits-all frameworks, limited avenues for correcting errors and a lack of meaningful engagement, often within resource-intensive processes or under tight timelines.

Market concentration warrants continued oversight and more proportionality in the regulation. The proxy advisory and ESG rating industries are dominated by a few global players with headquarters outside the EU, raising concerns about limited competition. Improving regulatory proportionality and monitoring in Belgium and at the EU level can help ensure that new firms enter these markets, services remain accessible, and providers uphold high standards of transparency and accountability in their methodologies and advice. Effective competition between European and non-European providers would also reduce the risk of overreliance on firms based in a single jurisdiction and, therefore, mitigate potential biases or vulnerabilities.

Data pricing also merits attention: ESG data and sustainability-related market data – offered by specialised vendors and, in some cases, by stock exchanges – can be costly. Greater price transparency and proportionate supervisory arrangements could support fair access while preserving incentives to invest in data quality.

3.7.1.  Proxy advisors

Strengthening oversight of proxy advisory firms could enhance transparency, accountability and the effective application of existing principles. Proxy advisors play an increasingly influential role in shareholder voting and governance, yet oversight remains limited both globally and in Belgium. To promote consistency and market confidence, minimum expectations for proxy advisor codes of conduct and a more prominent role for ESMA or NCAs could be considered. ESMA has encouraged a self-regulatory approach via the Best Practice Principles. At the national level, there is currently no designated NCA in Belgium to supervise proxy advisory activity. This means that regular courts and tribunals are competent for upholding the related provisions of the Code of Companies and Associations.

Clarifying the role of proxy advisors in the Belgian Corporate Governance Code. Principle 8.8 of the 2020 Belgian Corporate Governance Code refers to proxy advisors as “voting agencies” from whom companies may request explanations for voting behaviour. With a review of the Belgian Corporate Governance Code of 2020 under consideration, there is an opportunity to clarify this recommendation. While Principle 8.8 aims to encourage dialogue between companies and their shareholders, it could explicitly recognise proxy advisors as intermediary service providers that assist institutional investors in exercising their voting rights, making clear that investors – and not proxy advisors – are responsible for explaining their voting decisions.

Equitable access to proxy reports. At least one proxy advisor charges companies fees to access its reports or to request corrections. A more balanced practice, already seen with ESG rating providers under the EU framework, would require proxy advisors to share these reports with the companies they evaluate, ensuring that companies can review and respond to recommendations without undue cost.

Transparency of analytical capacity of proxy advisory firms. To instill more confidence among institutional investors and companies, proxy advisors could disclose more information about the size and expertise of their analytical teams. Such transparency would allow institutional investors to consider whether assessments possibly reflect a nuanced understanding of local market and company specificities, or if the advice provided follows analysis close to a checklist approach.

Enhancing conflict of interest disclosure by providing transparent information on revenue shares by business line. Proxy advisors generally maintain that the firewalls they have in place and their internal policies sufficiently prevent conflicts of interest between different business lines. Nevertheless, considering the absence of specific supervisory tools relating to proxy advisors by FSMA, ESMA and BPOC, encouraging more detailed disclosure of shares of revenues at the group-level by business line could ensure more transparency of proxy advisors’ business models and understanding by market participants of potential conflicts of interest in the recommendations and services provided.

Inclusion of company feedback in recommendations. Many proxy advisors currently do not revise their voting recommendations in response to feedback from companies. Policymakers could consider requiring or recommending proxy advisors to append any company commentary or clarifications to the reports they distribute to clients. This practice, already adopted by some proxy advisors and ESG rating providers in Europe and even mandatory for proxy advisors in jurisdictions like India, would ensure that investors receive the company perspective alongside the proxy advisory firm’s recommendation.

3.7.2. ESG rating providers

Improving transparency of methodologies and sector relevance can enhance trust and reduce unintended compliance behaviours. Issuers often struggle to understand how their ESG ratings are determined or why scores fluctuate. ESG rating providers publish their methodologies and criteria, but how they assess and weight those factors often remains opaque to both investors and rated issuers. While ESG rating providers have a legitimate interest in protecting their proprietary models, issuers often lack incentives to engage in technical debates that offer them limited direct benefit. ESMA could play a constructive role by assessing whether the level of methodological disclosure is sufficient to support meaningful comparability and accountability without compromising intellectual property. Under the EU ESG Rating Regulation, it remains unclear how rated issuers can request corrections. Feedback from market participants highlights that certain rating criteria are prone to box-ticking, undermining their effectiveness. For example, issuers may be rewarded for having a human rights policy, regardless of its implementation or relevance to their operations. In some cases, environmental policies are assessed without considering sector-specific impacts. A more nuanced regulatory approach, encouraging proportionality, sector relevance and transparency, could help ensure ESG ratings serve their intended purpose.

Harmonising and clarifying ESG rating update cycles. The timing of rating updates is another concern. ESG ratings are typically updated annually, but not on a uniform schedule as providers often stagger reviews without a clearly identified process or rationale. As a result, ratings are not always comparable even within the same provider, and the top-rated issuers in a sector might be, for instance, those that were updated most recently. Some stakeholders even suspect a “pay-to-play” dynamic, whereby issuers that pay for extra ESG services receive more frequent updates. Establishing more predictable and transparent update schedules could improve comparability across issuers.

Clarify scope and ensure proportionality of the new EU ESG Ratings Regulation. The EU framework to regulate ESG rating providers is a welcome step for market participants, but its design may still need fine-tuning to avoid unintended gaps or excessive burdens. ESMA’s role in the definition of Level II regulations through Guidelines or Questions and Answers will be key. In particular, ESMA may clarify exactly which entities fall under the definition of an ESG rating provider and what is a rating, to ensure consistent application. Certain rules – such as a nine-month cooling-off period before a rating firm’s senior staff can join a rated company – might be disproportionately onerous for this sector. A one-size-fits-all approach could overburden smaller providers, suggesting the need for a more calibrated, proportionate regime that aligns requirements with provider size and risk while still supporting transparency, independence and innovation.

3.7.3. ESG data providers

Addressing the regulatory gap for ESG data services. Investors increasingly rely on raw ESG data as much as on ratings for informed decision-making. With the recent EU Omnibus package aiming to reduce the number of companies that need to disclose sustainability information (European Council, 2026[20]), the role of third-party ESG data providers will become even more critical. However, these data providers remain outside the scope of the new ESG Ratings Regulation framework, creating a potential gap in their oversight. Policymakers might consider ways to bring key ESG data providers under an appropriate oversight framework or develop voluntary standards. Belgium’s FSMA dedicated webpage setting out good practices for ESG data providers is a welcome step in the right direction (FSMA, 2025[11]). This would help ensure the quality, consistency and reliability of the data feeding into ESG ratings and indices. IOSCO’s recommendations could serve as a useful source of inspiration for future regulation in this field (IOSCO, 2021[15]).

3.7.4. Index providers

Monitor index licensing costs for fairness. Belgium’s primary stock index, the BEL 20, is relatively limited in size, but it remains a valued benchmark domestically. More importantly, Belgian issuers and investors are influenced by inclusion in larger European and global indices that carry significant weight in markets. Stakeholders report no methodological issues with these indices, but they have flagged that major index providers often charge high fees for index data and licensing. Such costs, similar to high market data fees, could benefit from monitoring to ensure benchmarks remain accessible and not unduly burdensome.

References

[3] Belgium Corporate Governance Committee (2020), The 2020 Belgian Code on Corporate Governance, https://corporategovernancecommittee.be/assets/pagedoc/2003973319-1651062453_1651062453-2020-belgian-code-on-corporate-governance.pdf.

[6] BPPG (2025), Signatory statements, https://bppgrp.info/signatory-statements/.

[7] BPPG (2019), Best Practice Principles for Providers of Shareholder Voting Research & Analysis 2019, https://bppgrp.info/wp-content/uploads/2019/07/2019-Best-Practice-Principles-for-Shareholder-Voting-Research-Analysis.pdf.

[9] BPPOC (2025), 2025 Annual Report, https://bppgrp.info/wp-content/uploads/2025/11/BPP-Oversight-Committee-2025-Annual-Report.pdf.

[8] BPPOC (2024), 2024 Annual Report, https://bppgrp.info/wp-content/uploads/2024/11/BPP-Oversight-Committee-2024-Annual-Report.pdf.

[10] Centre for Strategy & Evaluation Services (2025), Study on the application of the shareholder rights directives, https://op.europa.eu/en/publication-detail/-/publication/834aae3d-eda9-11ef-b5e9-01aa75ed71a1.

[19] EC (2018), COMMISSION DELEGATED REGULATION (EU) 2018/1645, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1645.

[18] EC (2018), COMMISSION DELEGATED REGULATION (EU) 2018/1646, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1646.

[13] ESMA (2025), Technical Standards under the Regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, https://www.esma.europa.eu/sites/default/files/2025-10/ESMA84-2037069784-1184_Final_Report_on_Technical_Standards_under_ESG_Rating_Regulation.pdf.

[17] ESMA (2021), Guidelines on methodology, oversight function and record keeping, https://www.esma.europa.eu/sites/default/files/library/esma81-393-239_final_report_-_guidelines_on_methodology_oversight_function_and_record_keeping_under_the_benchmarks_regulation.pdf.

[5] ESMA (2015), Follow-up on the development of the Best Practice Principles for Providers of Shareholder Voting Research and Analysis, https://www.esma.europa.eu/press-news/esma-news/esma-publishes-report-proxy-advisors%E2%80%99-best-practice-principles.

[4] ESMA (2012), An Overview of the Proxy Advisory Industry. Considerations on Possible Policy Options, https://www.esma.europa.eu/sites/default/files/library/2015/11/2012-212.pdf.

[2] ESMA; EBA (2023), Implementation of SRD2 provisions on proxy advisors and the investment chain, https://www.esma.europa.eu/sites/default/files/2023-07/ESMA32-380-267_Report_on_SRD2.pdf.

[12] EU (2024), “Regulation (EU) 2024/3005 of the European Parliament and of the Council of 27 November 2024 on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities, and amending Regulations (EU) 2019/2088 and (EU) 2023/2859”, European Union Law, p. 48, https://eur-lex.europa.eu/eli/reg/2024/3005/oj/eng.

[16] Euronext Brussels (2024), Index Rulebook.

[20] European Council (2026), Directive on sustainability reporting and due diligence requirements, https://data.consilium.europa.eu/doc/document/PE-66-2025-REV-2/en/pdf.

[11] FSMA (2025), Fournisseurs de données ESG, https://www.fsma.be/fr/fournisseurs-de-donnees-esg.

[15] IOSCO (2021), Environmental, Social and Governance (ESG) Ratings and Data Products Providers Final Report, https://www.iosco.org/library/pubdocs/pdf/IOSCOPD690.pdf.

[14] NBIM (2025), ESMA Consultation on rules for ESG Rating Providers, https://www.nbim.no/en/news-and-insights/consultations/2025/esma-consultation-on-rules-for-esg-rating-providers/#_ftnref2.

[1] OECD (2025), OECD Corporate Governance Factbook 2025, OECD Publishing, Paris, https://doi.org/10.1787/f4f43735-en.

Note

← 1.  In Belgium the definition of controversial weapon contains anti-personnel mines, cluster munitions, depleted (or industrial) uranium per Art. 8(3) of Law of 8 June 2006 (as amended by the Law of 16 July 2009). This definition differs from the one of other EU Member States.