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This guideline outlines elements of good advisory practice as described by the AFM. It serves as an example of how an advisor can meet the legal requirements for providing suitable advice. This is a market consultation aimed at improving the guideline using insights from the Dutch mortgage market.

This document examines sustainability progress in the built environment, emphasizing the need for collaboration among residents, market parties, municipalities, corporations, and the national government to meet sustainability goals. Progress is stagnating, with new construction in 2024 lower than previous years due to economic conditions, capacity issues, and regulations. There has been only a limited increase in the percentage of natural gas-free homes. Energy prices remain high, with a new increase in 2025 surpassing pre-crisis levels. The end of temporary support measures has increased energy poverty, highlighting the need for affordability in a just transition to sustainability. Households slightly increased energy consumption in 2024, causing a minor rise in emissions. In the service sector, energy consumption remained stable, but emissions decreased. Heat network connections grew slowly in 2024, and heat pump sales dropped. Residential solar panel sales declined, but companies continue investing. Battery system sales rose, indicating the growing importance of flexibility and energy storage. These developments led to a slight increase in greenhouse gas emissions in 2024. Achieving climate and energy goals relies on the continued commitment of all stakeholders. eholders involved. We invite you to use this monitor as an objective basis for reflection and to take new steps together towards further sustainability of our built environment.

Over the past weeks, EEM HUB NL has contributed to the European Commission’s consultation on the “Energy-efficient buildings – portfolio framework to increase lending for renovations (delegated act)”. In our response, we focused on questions 12–25, reflecting the perspective of Dutch mortgage lenders and other financial institutions. Our input highlights, among others: - The current limitations in data availability and quality (e.g. reliance on EPC/EP-Online and the lack of access to underlying and actual consumption data), - The need for better governance and legal frameworks for data sharing, including GDPR-compatible solutions, - The potential of proxy data and intelligent data infrastructures to enable scalable, auditable renovation finance, - The importance of aligning the EU Taxonomy with EPBD IV to make “green” mortgage and renovation lending practically workable, - Targeted measures to support worst-performing buildings and vulnerable households, combining guarantees, subsidies and standardised products, and - The crucial role of one-stop-shops and independent advice in turning regulation into executable customer journeys. With this contribution, EEM HUB NL aims to support a framework that is not only ambitious on climate, but also implementable for financial institutions and meaningful for homeowners across Europe.