FMO has launched a public consultation for the proposed updates to its Sustainability Policy Universe (SPU). The Sustainability Policy Universe has recently undergone a review process with the aim of maintaining the clarity and ambition of FMO’s existing sustainability commitments, while ensuring the framework is up to date, robust and effective.
The SPU is FMO’s comprehensive policy framework that guides our approach to sustainable development finance. It consists of:
FMO reviewed the documents for consistency in terminology, both within the universe and across related frameworks and disclosures, and improved clarity of the documents. These changes are reflected throughout all documents of the SPU. These changes are not considered material policy changes and are not subject to public consultation.
Material revisions were made to the Sustainability Policy, the Combined Position Statement on Fossil Fuels, and the Human Rights Position Statement. Therefore, these three documents are subject to public consultation.
Key changes to the Sustainability Policy Universe
Key material changes include:
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Further clarifying the scope of application and differentiated implementation approach of the Sustainability Policy Universe explaining in more detail to what investments FMO applies the SPU and describing how contexts and leverage may affect the approach to implementation, including working with Partner institutions.
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Reflecting relevant internal operational developments, ensuring that the SPU remains up to date. For example, the updated SPU reflects that FMO assesses all new investments for alignment with the goals of the Paris Agreement, in line with FMO’s Methodology for Paris Alignment.
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Further explaining FMO’s risk-based approach. For example, the scope and depth of due diligence conducted, as well as the engagement of ESG specialists, depend on the risk category —as determined through the ESG Risk Categorization processes—and on the type, scope, scale, and likelihood of the negative impacts identified, as well as the extent to which such impacts may pose a threat to people, the environment, FMO’s customers, or FMO itself.
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A key update is that FMO will no longer make any new direct investments in gas‑fired power generation plants and directly connected transmission infrastructure, including transmission infrastructure solely connecting gas-based power to the grid, as the five‑year transition period for gas-based power FMO previously committed to, ends in June 2026. Renewable energy technologies have further advanced, and FMO chooses to invest its scarce resources in renewable energy.
Public consultation process
FMO invites stakeholders and interested parties to review the Sustainability Policy and the Combined Position Statement on Fossil Fuels, and Human Rights Position Statement, and share their comments and suggestions as part of the 30-day consultation period, beginning on 13 May 2026 and concluding on 10 June 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 framework will be considered for future reviews. Following the consultation period, FMO will review the feedback received and consider incorporating it into the final policy. The revised Sustainability Policy Universe is expected to be finalized following internal approval.
Please access the reading guide to key changes here.
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