news - FMO Opens Public Consultation on Revised Customer Disclosure Policy

FMO has launched a public consultation for its Revised Customer Disclosure Policy. The update delivers targeted technical adjustments to ensure disclosure requirements are aligned with FMO’s evolving investment process, accounting for complex, repeat, and syndicated transactions such as B-loans, frequent borrower frameworks, and listed bonds. This alignment ensures the policy accurately reflects how investments are structured, managed, and disclosed in practice and helps maintain a high standard for the quality and accessibility of project information.

FMO’s Customer Disclosure Policy is central to our commitment to transparency and accountability. It ensures that not only current investments, but also proposed investments are published, enabling stakeholders to understand what we aim to finance and why. By inviting feedback and additional information at key moments, the policy helps strengthen investment design and decision-making. FMO periodically reviews and updates the policy to ensure it remains clear, up to date, and aligned with current products and practices. While this revision does not introduce fundamental changes to FMO’s disclosure approach, it clarifies existing provisions and addresses practical questions that have emerged in practice.

Key Updates to the Customer Disclosure Policy

• B-loans: FMO now applies a shortened ex-ante disclosure period for B-loans, provided the A-lender has already disclosed the investment for the required duration. This approach makes syndicated loan disclosure more practical and avoids duplication.
• Frequent Borrower Frameworks: The revised policy explicitly recognizes Frequent Borrower Frameworks for financial institutions. Repeat investments under these arrangements can be exempted from ex-ante disclosure via waiver, provided the Framework’s existence is ex ante disclosed at approval, streamlining reporting for ongoing relationships.
• Listed Group Customers: Customers that are not listed but are part of a listed group are now exempted by default from ex-ante disclosure. This removes the need for a waiver and reflects how group structures are managed in practice.
• Repeat Deals, Renewals, and Listed Bonds: Exemption criteria for routine renewals and listed bond investments have been sharpened. Refinancing or renewal of existing working capital facilities may be exempted via waiver if there is no material change, and listed bonds are now explicitly recognized as cases where disclosure may disrupt the commercial process.
• Policy Structure and Development Contribution: The update improves the overall structure and readability of the policy, clarifies the distinction between ex-post and completed investments, and explicitly includes Development Contributions in the disclosure framework.

Public Consultation

FMO invites stakeholders and interested parties to review the Draft Revised Customer Disclosure Policy and share their comments and suggestions as part of the 30-day consultation period, beginning on 23rd April 2026 and concluding on 23rd May 2026.

Comments can be submitted by email to consultation@fmo.nl. This consultation focuses on the key updates introduced in this revision; broader suggestions on the overall policy will be considered in future reviews. Following the consultation period, FMO will review the feedback received and consider incorporating it into the final policy. The revised Customer Disclosure Policy is expected to be finalized following internal approval.

Access the policy here.