On 2 May 2025, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published an annex (the Annex) to its guidelines on the Act on the Prevention of Money Laundering and Terrorist Financing (Wet ter voorkoming van witwassen en financiering van terrorisme, the Wwft), the

Ademir Šehomerović
AFM’s expectations on the implementation of the European Accessibility Act
On 24 April 2025, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published a news update concerning the European Accessibility Act (Directive (EU) 2019/882, the EAA), which will become applicable in the Netherlands as of 28 June 2025. In this news item, the AFM urges financial institutions…
The Dutch draft bill implementing the revised AIFMD and UCITS Directive
On 9 April 2025, a public consultation was launched for the draft bill to implement the revised Alternative Investment Fund Managers Directive (Directive 2011/61/EU, the AIFMD) and the Undertakings for Collective Investment in Transferable Securities Directive (Directive 2009/65/EC, the UCITS Directive).
The draft bill introduces new rules for alternative investment funds (AIFs…
AFM launches an exploratory investigation into services provided under the Dutch ‘national regime’
On 2 April 2025, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) announced the launch of an exploratory investigation into financial services provided under the so-called ‘national regime’ exemption. This regime allows financial service providers and investment firms in the Netherlands to provide (i) investment advice and (ii)…
Consultation on the implementation of CSDDD into Dutch law
On 18 November 2024, the Ministry of Foreign Affairs (Ministerie van Buitenlandse Zaken) published its consultation on the draft bill of the Corporate International Responsibility Act (Wet internationaal verantwoord ondernemen) (the Act). The Act will implement the EU Corporate Sustainability Due Diligence Directive (Directive 2024/1670, the CSDDD), into Dutch…
Asset managers and investment advisors still not always ask about investors’ sustainability preferences
On 12 November 2024, the Dutch Authority for the Financial Markets (Autoriteit Financiele Markten, AFM) published its Consumer Monitor Investors report (Consumentenmonitor Beleggers). The key message in the report is that not all asset managers and investment advisors comply with the obligation to ask investors about their sustainability preferences. Only 25%…
AFM explorative study into ESG data risk management
On 28 October 2024, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published the results of an explorative study (in the form of a report) into how asset managers deal with the availability, reliability and comparability of Environmental, Social and Governance (ESG) data. The study…
DNB urges pension funds to address ESG Risks
On 28 October 2024, the Dutch Central Bank (De Nederlandsche Bank, DNB) published their findings from its sector-wide self-assessment on Environmental, Social, and Governance (ESG) risk integration among pension funds. The report reveals that while many pension funds have taken steps to incorporate ESG risk into their policies, there is still a…
ESAs respond to the EC’s rejection of the draft ITS on the register of information under DORA
On 15 October 2024, the European Supervisory Authorities (ESAs) issued an opinion regarding the European Commission’s (EC) rejection of the draft Implementing Technical Standards (the Draft ITS) for the register of information under the Digital Operational Resilience Act (Regulation (EU) 2022/2554, DORA). DORA requires financial entities to maintain and…
DORA – DNB guidelines on the template for the register of information
On 22 August 2024, the Dutch Central Bank (De Nederlandsche Bank, DNB) published guidelines on the information register required under the EU’s Digital Operational Resilience Act (Regulation (EU) 2022/2554, DORA). According to DORA, financial entities must maintain a register of all contractual agreements with ICT third-party service providers. This register is essential…