The Dutch Central Bank (De Nederlandsche BankDNB) has announced that it will send a questionnaire to banks and insurers to further evaluate the Financial Institutions Remuneration Policy Act (Wet beloningsbeleid financiële ondernemingen, Wbfo).

The questionnaire is a component of a broader assessment examining the influence of the Wbfo on the establishment of banks and the evolution of remuneration in the financial sector, focusing on the performance years 2019 and 2022. This evaluation, commissioned by the Dutch Ministry of Finance, is the second assessment of the Wbfo, following an initial evaluation in 2018. After the first evaluation, the Minister of Finance suggested that it was premature to derive definitive conclusions regarding the impact of the Wbfo. The new evaluation will focus on two main questions:

  1. What is the impact of the Wbfo on the development of remuneration in the financial sector?
  1. What are the effects of the Wbfo on the competitive position of financial institutions to which it applies and on the business climate and labour mobility?

DNB invites banks and insurers to voluntarily participate in the questionnaire. The questionnaire specifically focuses in particular on questions regarding the allocation and amount of variable remuneration and the utilisation of exceptions to the bonus cap. It also includes an open-ended question where participants can share their perspectives on the impact of the Wbfo on the business environment, labour mobility, and remuneration trends.

The Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) will administer the same questionnaire to financial services providers and investment firms.The questionnaire will be conducted anonymously during Q1 2024.

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Photo of Nikolai de Koning Nikolai de Koning

Nikolai de Koning is a financial services lawyer (advocaat) based in Amsterdam. Nikolai is experienced in financial services and banking law, as well as in data privacy (protection). He is experienced in advising on regulatory and compliance aspects relevant to financial…

Nikolai de Koning is a financial services lawyer (advocaat) based in Amsterdam. Nikolai is experienced in financial services and banking law, as well as in data privacy (protection). He is experienced in advising on regulatory and compliance aspects relevant to financial institutions, such as insurance companies, investment firms, clearing institutions and central counterparties. Nikolai also advises on Dutch licence and notification requirements and he assists companies in their licence or notification processes with the Dutch financial regulators. He also specialises in privacy issues arising out of online products, data protection and e-commerce.

Photo of Julia van der Grint Julia van der Grint

Julia van der Grint is a financial services lawyer based in Amsterdam.

She advises clients on a wide range of regulatory and compliance aspects relevant to financial institutions, such as investment firms, trading platforms, payment institutions, insurers, fund managers and clearing and settlement…

Julia van der Grint is a financial services lawyer based in Amsterdam.

She advises clients on a wide range of regulatory and compliance aspects relevant to financial institutions, such as investment firms, trading platforms, payment institutions, insurers, fund managers and clearing and settlement institutions. Julia has developed particular knowledge of blockchain and cryptocurrencies, and advises crypto-asset services providers, crypto exchanges, payments providers and financial institutions on the regulatory issues related to the deployment of these technologies. She also advises on Dutch licence application and notification requirements and assists companies in their licence or notification processes with the Dutch Authority for Financial Markets and the Dutch Central Bank. Additionally, she assists companies in their contacts with these supervisory authorities and represents companies in enforcement procedures.

In addition, she has previously advised banks, other financial institutions and corporates in an array of transactions, both domestic and cross-border. This includes, among others, advising lenders and lender-groups in corporate restructurings and other insolvency related matters.

Prior to joining the team as an associate, Julia gained experience with the Amsterdam office as a student worker.