On 30 September 2025, an amendment to the Regulation on supervisory costs of one-off actions (the Supervisory Costs Regulation) was published. The Regulation increases the rates charged by the Dutch Central Bank (De Nederlandsche Bank, DNB) for one-off supervisory actions. One-off supervisory actions are, for instance, screenings of (co-)policymakers and applications for a declaration of no-objection (verklaring van geen bezwaar, DNO).

The main reason for this amendment, is that the fees for one-off activities have not been indexed since 2012. Any costs of activities not covered by these fees were charged as part of the ongoing supervision charges for the relevant category of regulated entities. For this reason, the sector has indicated that the fees for one-off activities need to be increased. The fees will now be indexed annually.

The explanation to the amendment also refers to a recent judgment of the Dutch Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven) in which it ruled that DNB may not include the costs of one-off supervisory activities in its fees for ongoing supervision. This judgment has not yet been considered as part of the amendment and will be addressed at a later stage.

Most notably, the structure for the fees charged for granting a DNO has been simplified. Instead of different multiple rate brackets for various sectors, one fixed fee applies for all types of DNO applications.

The amended Supervisory Costs Regulation is available here.

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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.