No significant changes have taken place in the definition of what constitutes the reporting undertaking and its value chain. The financed emission calculations have benefitted from data improvements and methodological refinements compared to the previous Annual Report. The adjustments are elaborated upon in the FMO methodology for reporting financed GHG emissions and jobs, which is available on FMO’s website.

FMO follows the GHG Protocol Corporate Standard to report its GHG emissions scopes 1, 2 and 3. The absolute GHG emissions from FMO’s own operations are calculated based on measured data collected internally, such as information on commuting and flights and heating consumption of the FMO office in The Hague.

To report on the scope 3 category 15 emissions (i.e. the financed absolute GHG emissions), FMO follows the Global GHG Accounting and Reporting Standard for the Financial Industry published by the Partnership for Carbon Accounting Financials (PCAF).29 The reporting boundary includes the debt and equity portfolio at the time of reporting, and excludes the treasury/liquidity portfolio. The majority of FMO’s financed absolute GHG emissions are estimated through economic modelling using the Joint Impact Model (JIM). The JIM version used only allows to calculate two financed Scope 3 categories, namely 'Purchased goods and services' and 'Investments'. For more details, please refer to the FMO methodology for reporting financed GHG emissions and jobs, which is available on FMO’s website.

Financed emissions are calculated based on the most recent data available from customers. For the Annual Report 2025, this means that numbers reflect customer data for 2025 to the extent that information is available, and otherwise 2024 (or older) data. Customer data is recorded per year. In other words, if the reporting date of the client is March 31, 2025, the data is reported for the year 2025 and similarly for customers where the reporting date is December 31, 2025. When investments are no longer in the portfolio as of December 31, 2025, we no longer include emissions of these customers.

Information about the percentage of different contractual instruments within scope 2 is not provided, since scope 2 emissions were found to be non-material by the DMA.

The percentage of financed emissions calculated using primary data is disclosed in table 20a and 20b. The tables also include information on the coverage percentage and the PCAF data quality score.

Biogenic emissions of CO₂ from combustion or bio-degradation of biomass that occur in value chain are included in the gross scope 3 emissions, as data limitations do not allow to disclose these separately.

The net revenue figure was calculated by summing the line items 'Interest income from financial instruments measured at AC' (amortized cost), 'Interest income from financial instruments measured at FVPL' (fair value through profit or loss), 'Dividend income', 'Fee and commission income' and 'Remuneration for services rendered' from the financial statements (see 'Consolidated statement of profit or loss' in the 'Consolidated Financial Statements' chapter).

Table 21. GHG intensity per net revenue

E1-7 GHG Removals and GHG mitigation projects financed through carbon credits

In the downstream value chain, FMO invests in projects that contribute to GHG removals and storage. As per FMO’s 2030 Strategy, Climate Action Plan and Forestry Strategy, we will increase our contribution to GHG removals and storage, by investing more in, for example, forestry. Specifically, FMO’s Forestry strategy was launched in 2023 and aims to grow investments in forestry, including nature-based solutions, sustainable natural forest management, and greenfield plantations. Projects that contribute to GHG removals and storage are moreover eligible for FMO’s Green Label.

FMO does not yet quantitatively report on emission removals through these activities. This is something that is being worked on for future reporting.

Even though operational emissions were found to not be material during the DMA, FMO offsets its operational emissions from business travel by investing in a mix of different carbon credits. In 2025, FMO has offset 5,615 tons of CO₂e using Verified Carbon Standard (VCS) Landfill Gas Pichacay Ecuador credits and 600 tons of CO₂e VCS REDD+ (reducing emissions from deforestation and forest degradation in developing countries) Forestry credits.

It should be noted that no carbon credits are used to claim emission reductions towards the Power Generation Emission Reduction Target. The offset emissions are also not deducted from the operational emissions reported in section 'E1-6 Gross Scope 1, 2, 3 and Total GHG emissions'. In other words, we report our gross operational emissions.

Within our own value chain, FMO invests in activities that contribute to carbon removals, including forestry investments. Currently, we are choosing to not quantitatively assess the GHG removals across our investment portfolio. This decision reflects our intention to await further clarity on global standards before choosing an appropriate GHG accounting tool or methodology. Relevant guidance includes, for example, the recently published GHG Protocol on Land Sector and Removals Guidance, which we will further analyze.

The carbon credits FMO acquires are all retired on a yearly basis. These carbon credits do not originate from FMO's customers and are therefore outside FMO's value chain. FMO plans to keep offsetting its market-based operational emissions by purchasing carbon credits, but there are no contractual agreements for future purchase of carbon credits.

FMO has committed to be Net Zero by 2050. FMO strives to align financial flows with 1.5ºC aligned activities so that we are on track to be Net Zero by 2050. In 2025 we piloted a qualitative approach in order to measure portfolio alignment. In the short-term, FMO does not utilize emissions removals to reach Net Zero financed emissions, but we will monitor industry developments in this regard. FMO will continue to improve our data collection for financed emissions, including at the level of our customers, and use it to assess our progress.

FMO strives to remain climate neutral in all its operational activities, through energy efficiency, sustainable energy procurement and compensation through the use of carbon credits. FMO's operational emission neutralization initiative does not affect the set reduction targets because carbon credits or removals do not count as emission reductions. Moreover, FMO's material emissions take place in the downstream value chain. While FMO's operational emissions are not subject to an emission reduction target, they are considered part of its net zero ambition.

FMO entity specific metrics – climate change

In addition to ESRS-specific metrics on emissions, FMO reports on Green-labelled new investments and financed avoided GHG emissions.

Green-labelled new investments

The Green Label Guidelines provide criteria and a methodology to assess new investments for their eligibility for FMO’s Green Label. The Green Label is a strategic steering tool and a proxy for us to measure progress against the €10 billion SDG 13 target and includes, but is not limited, to climate change. The metric disclosure for Green-labelled total new investments is presented in 'ESRS 2 - IRO management'.

Financed avoided GHG emissions

Avoided emissions are the reduction in systemic emissions resulting from a project, product, or service compared to a counterfactual scenario. For example, emissions can be avoided by renewable power production that is assumed to displace fossil fuel-based power plants, or emissions avoided through the protection of forests against illegal logging. The financed avoided GHG emissions metric aims to quantify our contributions to climate change mitigation activities. A significant proportion of avoided emissions was attributable to our debt and equity portfolios in on-grid renewable power projects. While this metric is not defined under the ESRS, financed avoided emissions is an important entity-specific metric for FMO and its stakeholders and further defined in Table 22. Table 23 disaggregates the financed avoided emissions per strategic sector, funding source, product and project type.

Table 22. Minimum Disclosure Requirements for Metrics for Financed Avoided Emissions

Table 23. Results on Financed Avoided Emissions

EU Taxonomy

For the financial year 2025, FMO will opt out from detailed reporting in accordance with the EU Taxonomy, as no activities are claimed as being associated with economic activities that qualify as environmentally sustainable under Articles 3 and 9 of Regulation (EU) 2020/852 (Taxonomy Regulation).