AFM supervision 2026: fund manager guide
The scope of the supervision is quite broad, covering all sustainability-related investment products, whether or not they are structured under SFDR, and applies to both mandatory regulatory disclosures and non-mandatory communications, including marketing materials, website content, and factsheets.
For fund managers, the most important question is: does your fund communication align with its contents, and can every sustainability claim be verified by a regulator who looks closely enough?
In this article:
What the 2026 AFM supervision programme involves
Core principles sustainability claims are assessed against
What the AFM considers a violation + documented examples
What fund managers should prioritise immediately
What is happening in 2026
This year, AFM will conduct a joint supervisory investigation in collaboration with Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) and European Securities and Markets Authority (ESMA). The investigation is designed to test whether funds actually deliver on their sustainability claims. Going beyond reviewing policy documents, regulators examine portfolio holdings directly and compare them with SFDR classifications, stated ESG strategies, and PAI indicators to identify major discrepancies. Running alongside the investigation, the AFM is developing automated web-scraping tools that will continuously collect and assess sustainability information from fund websites, product pages, factsheets, and marketing materials against the SFDR regulation.
The investigation is conducted as continuous monitoring rather than a one-time review. This means that any sustainability claim visible online is subject to automated assessment at any point, with the AFM able to intervene wherever it identifies information that is incomplete, inconsistent, or potentially misleading. A similar approach applies to how funds name their product. The AFM will verify that terms such as "sustainable", "ESG", and "impact" are used in fund names only where the underlying investments and strategy support those labels.
The AFM has also signaled increased attention to the quality and consistency of ESG data used in SFDR disclosures. As CSRD reporting takes hold across large EU companies and progressively expands in scope, the reporting by investee companies is likely to become more prevalent. In response, funds should expect growing scrutiny of whether what they disclose at the fund level is consistent with what their investee companies report under CSRD.
The three principles AFM will focus on
In October 2023, the AFM published its Guidelines on Sustainability Claims, establishing three principles for communicating sustainability for financial institutions. Exploratory supervision across the market revealed recurring shortcomings in specificity and substantiation, which is why in 2026, the AFM agenda committed to intensified scrutiny and sanctions where violations are found. Below is what each of those three principles requires from your fund.
Principle 1: accurate, representative and up to date
The starting point is simple: what a fund communicates must match what it does in practice, across every channel and every document produced. A claim becomes non-compliant the moment it contradicts information provided elsewhere, whether that contradiction appears within a single document or between different materials such as a website, annual report, and SFDR disclosure.
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Principle 2: claims need to be specific and substantiated
Vagueness of claims is the most common failure the AFM has documented, and it is worth understanding why it matters beyond just compliance. Statements like "we think a sustainable world is important" or "part of our investments follow our sustainable investment policy" create expectations in investors that the fund may not be well-positioned to meet. The prior makes no commitment. The latter fails to specify what proportion of assets is involved, what the policy contains, or how it is applied.
What does this mean for investors of the funds?
When investors realise the claims they based their decisions on were insufficiently grounded, the damage to trust tends to outlast any regulatory sanction. Getting this right means ensuring every claim is substantiated with up-to-date, relevant, and verifiable evidence that is immediately accessible at or adjacent to the claim itself. Where more detail is needed, it can be presented in layers, but each layer must hold up to the same standard.
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Principle 3: make your claims understandable, appropriate, and easy to find
For investors, the words a fund uses to describe itself carry immediate implications. Terms like "ESG", "green", "sustainable", "social", and "impact" create expectations about what the product stands for. The AFM requires that these terms be used only where they authentically define the product, and in the case where they apply only part of the portfolio, that scope must be stated clearly.
Falling short of this criteria is one of the clearest indicators of greenwashing risk the AFM looks for, and in 2026, automated tools will be scanning fund resources continuously for exactly these kinds of inconsistencies. Whether investors can actually reach the evidence is just as important as whether that evidence exists. The AFM has documented a case where evidence for a sustainability claim was scattered across a 45-page policy document with no clear structure, leaving investors with no practical means of finding data. In another instance, four sequential steps separated an investor from the evidence behind a single claim. Both are treated as violations, as substantiation an investor cannot reach is, from their perspective, no substantiation at all. Thus, supporting information must be reachable through a direct link at or adjacent to the claim itself, and any documents referenced must be available on the fund's website and structured for navigation.
What funds should prioritise now
The most useful thing a fund manager can do right now is sit down with their SFDR disclosures, their sustainability claims, and their portfolio, and ask where they do not align. That means reviewing all sustainability claims across every channel, from SFDR templates and factsheets to website copy, against the three AFM principles. Long-term objectives need to be reviewed for completeness, any climate or biodiversity commitment that lacks interim targets, a credible path to delivery, or disclosure of reliance on uncertain technologies is a liability under current AFM expectations.
Internally, the work of ensuring compliance cannot sit with a single team. Portfolio management, risk, communications, legal, and compliance functions need to be operating from the same picture of what the fund communicates and what it holds. The shorter the distance between claims and contents, the more likely the fund is to comply with sustainable regulations. Keeping that distance small, consistent and at a portfolio scale, is exactly what Impatec's Impact and Sustainability Software is built for.