FMO has published its revised Customer Disclosure Policy and accompanying public consultation report following a public consultation, reinforcing its commitment to transparency and accountability. The revised policy updates and clarifies aspects of FMO's disclosure requirements to reflect current investment practices and implementation experience. The report summarizes stakeholder feedback and outlines how this feedback has been considered in the policy review process and related disclosure practices.
FMO’s Customer Disclosure Policy is central to its approach to transparency. The policy ensures that both current and proposed investments are disclosed, enabling stakeholders to understand what FMO aims to finance and why, and to provide informed input. The revision forms part of FMO’s regular policy review cycle and introduces targeted updates to clarify existing provisions, with no material changes to FMO’s existing approach to customer disclosure. The revised policy was approved by FMO's Management Board on 30 March 2026 and is now in effect.
The policy introduces targeted updates to clarify the application of ex-ante disclosure requirements. These include a shortened disclosure period for B-loans where the A-lender has already disclosed the investment, recognition of Frequent Borrower Frameworks allowing repeat investments under these arrangements to be exempt from ex-ante disclosure, and a default exemption for customers that are part of a that are part of a group listed on a stock exchange. The policy also provides greater clarity on exemptions and waiver criteria for repeat deals, renewals, refinancing transactions, and listed bond investments.
The consultation feedback received during the consultation covered topics including disclosure exemptions, accountability for exemption decisions, transparency relating to financial intermediary investments and the accessibility of disclosed information. As outlined in the public consultation report, FMO will begin tracking disclosure waivers and exemptions and publish an annual external summary. In response to feedback on accessibility, FMO will also explore opportunities to improve access to disclosure information, including the use of machine-based translations.
FMO appreciates the input received from stakeholders during the consultation process. The feedback will help inform future policy reviews and disclosure practices.
