DNB sets deadline for pension funds that have not yet conducted ESG risk analysis
15 July 2025
Pension funds that have not yet carried out an ESG risk analysis have been requested to do so by 1 September 2025 at the latest, in accordance with the legal obligation under Section 135 of the Pensions Act. De Nederlandsche Bank (DNB) has since sent targeted letters to the funds concerned. For pension funds that did conduct a risk analysis, no additional action is required at this time.
An ESG risk analysis focuses on climate and nature risks, human rights and social relations. Has your pension fund not (yet) carried out the risk analysis (in full)? Read more about our targeted approach.
Our approach: structured and targeted
Our approach aims to provide you with maximum support over the coming weeks. Using a structured approach, we work towards a final report that you can submit to De Nederlandsche Bank on time. The timeline is as follows:
- Week 1-2: Preparation and initial analysis
These weeks are dedicated to identification. We start with a kick-off meeting, collect relevant data and clarify ESG risks.- Climate and natural risks: What physical risks arise from extreme weather? What are the transition risks due to policy changes? And what reputational risks does your organisation face in case of insufficient sustainability commitment?
- Human rights and social relations: we assess the impact of your investment portfolio on human rights and social relations.
Week 3-4: Risk assessment and scenario analysis
We then score and assess these risks and prioritise them for urgency and develop
scenarios to evaluate the potential impact of risks.
Week 5-6: Integration and policy-making
The findings are integrated into risk management and incorporated into a draft report.
Week 7: Review and finalisation
Presentation of results, processing feedback and finalising the report - ready for submission to DNB
Sustainable value
This approach not only enables you to submit the ESG risk analysis on time, but also represents a valuable long-term investment. The methodology is structurally deployable and remains relevant even after this call.
Forvis Mazars: your partner in ESG risk analysis
DNB's request requires a thorough and independent ESG risk analysis - a process that requires time, expertise and a multidisciplinary approach. Thanks to our combined knowledge of Risk and Sustainability, we ensure that your pension fund complies with statutory requirements and is prepared for future developments. We offer practical, directly applicable solutions.
Contact us to find out how we can support you.
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