In our EMEA regulatory insights series colleagues from our EMEA offices provide an update on some of the key regulatory issues they are seeing in their local market. In this latest episode Floortje Nagelkerke and Nikolai de Koning from our Amsterdam office provide a regulatory update for the Netherlands. This includes the AFM’s strategy 2023-2026
EBA consults on draft RTS for AMLA operations
On 6 March 2025, the European Banking Authority (EBA) published a consultation paper setting out draft Regulatory Technical Standards (RTS) as part of its ongoing implementation of the EU’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) package. The draft RTS will be part of the EBA’s response
AFM Reminder: Licensing Requirement for Group Insurance Providers
On 28 February 2025, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) reminded companies offering group insurance policies of the upcoming licence requirement, effective 1 October 2025. This requirement follows a 29 September 2022 ruling by the Court of Justice of the EU, clarifying licensing obligations for group
Instant Payments Regulation: an update from DNB
On 18 February 2025, the Dutch Central Bank (De Nederlandsche Bank, DNB) posted an update on the Instant Payments Regulation (IPR). The IPR entered into force on 8 April 2024 and payment service providers (PSPs) needed to comply with a first set of obligations from 9 January 2025, with more
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
Increase in AIFM-Light Managers and their assets under management in the Netherlands
On 30 October 2024, the Dutch Authority for the Financial Markets (Autoriteit Financiele Markten, AFM) released findings from its exploratory study on the rising number of fund managers operating under the so-called Alternative Investment Fund Managers Directive (AIFMD) light regime. The AIFM-light regime applies to smaller fund managers with assets under €100 million
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
Crypto Supervision: Minister opts for minimal supervision scenario with increased risk tolerance
Following an article published in the Dutch Financial Times on 28 July 2024, members of the Dutch Parliament submitted questions to the Minister of Finance regarding the upcoming crypto supervision by the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, AFM) under the Markets in Crypto-Assets Regulation (MiCAR). The