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.