On 28 February 2019, the Dutch Central Bank (De Nederlandsche Bank, DNB) published a brief update on Brexit.
In its new items, DNB emphasis that the risk remains that the United Kingdom leaves the European Union without a political agreement on 29 March 2019 and that financial institutions need to ensure that they are prepared to deal with upcoming (regulatory) challenges. DNB held a survey among insurers, less significant institutions, pension funds and asset managers in the second half of 2018. The outcome of the survey reveals that the majority of Dutch financial institutions have a Brexit contingency plan in place, varying in terms of depth and focus. The survey results prompted DNB to take individual follow-up action to verify the progress institutions made in implementing the measures set out in their Brexit plans. Most financial institutions have made a start with implementation.
DNB also points out that the European Central Bank requested significant institutions (SIs) supervised under the SSM to submit their Brexit plans and contingency measures for assessment, and that DNB was actively involved and in direct contact with SIs about their preparations. Finally, according to DNB, despite these contingency plans and measures, risks remain. For example, LSIs could still face Brexit risks in the area of outsourcing or the exchange of personal data. DNB therefore emphasis that it is imperative that financial institutions keep preparing for a no-deal Brexit and implement their plans as long as the political uncertainty continues.