Investment Management regulatory updates from Netherlands.
We track 24 Investment Management updates from Netherlands regulators, published by AFM. The archive covers 18 news items, 3 enforcement actions and 2 speeches. Most recent update: September 2026.
De naleving van de normen uit de Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) en de Sanctiewet (Sw) door beheerders van beleggingsinstellingen is op belangrijke onderdelen verbeterd. Dat blijkt uit de vragenlijst van de Autoriteit Financiële Markten (AFM) over 2024. (Een groot deel van) de…
Why this matters
This is a regulatory news item reporting AFM's 2024 questionnaire findings on Wwft (AML) and Sanctiewet compliance by investment fund managers (AIFM). The update identifies specific compliance gaps (66% lack transaction profiles, 55% unregistered with FIU-Nederland, ~45% of daily policymakers lack Wwft training),...
The financial sector has made major progress since the introduction of the Digital Operational Resilience Act (DORA). At the same time, as a result of its supervision and requests for information, the Dutch Authority for the Financial Markets (AFM) has identified areas requiring further action from financial…
Why this matters
AFM regulatory update on DORA compliance progress and implementation gaps. Informational content summarizing sector-wide developments, compliance improvements (94% register approval), and areas requiring attention (incident reporting, policy documentation, threshold calculations).
Many fund managers have their compliance and internal audit functions well organised. Nevertheless, improvements are needed. For example, documentation is not always up to date, fund managers do not always retain sufficient control when outsourcing, and decisions based on proportionality are often insufficiently…
Why this matters
AFM guidance on compliance and internal audit function improvements for fund managers. Addresses documentation quality, outsourcing oversight, and proportionality justification. Informational supervisory guidance from European Common Supervisory Action (CSA) coordinated by ESMA.
The Dutch Authority for the Financial Markets (AFM) and the French Autorité des Marchés Financiers (AMF) support the European Commission’s proposals to strengthen supervisory convergence and market integration through the Market Integration and Supervision Package (MISP). As discussions on the future of European…
AI Analysis
AFM and AMF have issued a joint position paper supporting the EU Commission’s Market Integration and Supervision Package (MISP) and setting out **five enablers** they see as conditions for effective, centralised EU‑level supervision by ESMA. This matters for compliance teams because it signals a medium‑term shift towards more **risk‑based, data‑driven, and ESMA‑centric supervision**, with impacts on funding models, governance expectations, data and reporting architecture, and enforcement across all major EU capital‑markets activities.
Key dates
22 July 2026
– AFM/AMF joint press release and position paper “From design to delivery – five enablers for effective European supervision” published, formally articulating the five enablers for centralised EU‑level supervision under the MISP
TBD (MISP legislative timeline)
– Specific dates for adoption and phased implementation of the Market Integration and Supervision Package will follow the EU legislative process; firms should anticipate a multi‑year transition with key milestones likely aligned to ESMA governance and funding reforms and initial scopes of direct supervision
Suggested considerations
Review and update the firm’s supervisory engagement strategy to include structured, proactive engagement with ESMA (not just NCAs), anticipating more direct interactions, thematic reviews, and data requests at EU level.
Assess current risk‑assessment and risk‑reporting frameworks to ensure they are compatible with a risk‑based and adaptive supervisory approach, including the ability to demonstrate how your firm identifies, measures, and mitigates emerging risks and new business models.
Conduct a gap analysis of data architecture and regulatory reporting, focusing on data quality, standardisation, and ability to feed into centralised EU data hubs; plan upgrades to systems, controls, and data governance to support ESMA‑level data centralisation.
Prepare for potential changes in supervisory levies and funding, by modelling the impact of EU‑level ESMA fees in addition to national contributions and incorporating them into medium‑term budgeting and pricing strategies.
Review governance arrangements, including board oversight, senior management responsibilities, and internal escalation processes, to ensure they can meet higher expectations of independent, transparent, and accountable governance under an ESMA‑centric model.
What changed
- ESMA is explicitly positioned as the central supervisory authority for selected capital‑markets activities, with national competent authorities (NCAs) expected to operate within a more formalised...
Supervisory objectives are reframed towards risk‑based and adaptive supervision, meaning firms should expect more differentiated supervisory intensity based on risk profile, business model, and...
The paper supports proportionate and transparent funding for ESMA, indicating a future where firms may be subject to EU‑level supervisory levies or fee structures in addition to national regimes,...
AFM and AMF call for independent, transparent, and accountable EU‑level supervisory governance, foreshadowing changes to ESMA’s decision‑making bodies, oversight processes, and accountability...
Data centralisation is identified as a core enabler, implying a stronger move towards EU‑wide data hubs, harmonised reporting formats, and central access for ESMA to transaction, position, and...
Compliance impact
The immediate impact is strategic rather than operational, but non‑compliance with future ESMA‑level requirements on data, governance, and cross‑border conduct could lead to EU‑wide enforcement, higher sanctions, and constraints on passporting and market access. Early alignment with the five enablers will position firms better for the coming supervisory architecture and reduce transition risk once binding rules are adopted.
Leren is hard werken, stelt bestuursvoorzitter Laura van Geest in haar periodieke column in Het Financieele Dagblad . Ze stelt dat dat geldt voor de eindexamenkandidaten het afgelopen jaar, voor de betrokkenen bij het coronabeleid en ook voor de financiële sector en haar toezichthouder. De column van Laura van Geest…
Why this matters
This is an opinion column by AFM Chair Laura van Geest discussing regulatory supervision philosophy and learning culture in financial services. It addresses how supervisors can balance enforcement with growth-oriented approaches, using examples from banking (anti-money laundering) and accounting sectors.
Per 19 juni treedt de herziene Distance Marketing of Financial Services Directive (DMFSD) in werking. De DMFSD bevat regels ter bescherming van consumenten bij het online sluiten van overeenkomsten voor financiële diensten. De regels gaan over precontractuele informatie, een ontbindingsrecht voor consumenten en…
Why this matters
AFM regulatory guidance on DMFSD implementation (effective 19 June 2024) regarding consumer protection in online financial services. Addresses dark patterns and manipulative design in digital customer journeys across multiple financial sectors.
In its SREP Market Overview 2025, the AFM notes that many firms have their foundations in order, but that implementation is lagging behind. Internal control and IT risks, in particular, require improvement. The message is clear: ensure that policies are not merely in place, but that they demonstrably work in practice.
Why this matters
AFM's SREP Market Overview 2025 provides regulatory guidance on implementation gaps in internal controls, IT risk management, and governance. This is informational content highlighting supervisory expectations rather than announcing new rules.
This is a general newsletter subscription announcement from AFM highlighting their commitment to fair and transparent financial markets. It contains no specific regulatory requirements, deadlines, or actionable guidance.
This is a general newsletter announcement from AFM promoting fair and transparent financial markets. It contains no specific regulatory requirements, deadlines, or actionable guidance. The content is informational and promotional in nature, addressing the AFM's broad mandate across multiple sectors and firm types.
Advanced AI models can speed up the process of identifying and combining vulnerabilities. As a result, organisations have less time to address vulnerabilities and mitigate incidents. Small and medium-sized enterprises in particular, with less advanced security or older systems, may be relatively more vulnerable. The…
Why this matters
AFM speech addressing AI-driven cyber threats and resilience requirements. Applies broadly across financial services sectors with emphasis on vulnerability management, patch management, and incident response. Classified as informational/advisory content rather than binding regulation, hence null urgency.
This is a general newsletter subscription announcement from AFM (Dutch financial regulator) emphasizing their commitment to fair markets and market conduct. No specific regulatory requirement, deadline, or enforcement action is mentioned. Content is informational/promotional in nature, therefore urgency is null.
Met een aantal aandachtspunten wil de Autoriteit Financiële Markten (AFM) financiële ondernemingen wijzen op de omgang met cliëntenonderzoek bij politiek prominente personen, politically exposed persons (PEPs). Uit een AFM-onderzoek blijkt dat ondernemingen bijvoorbeeld niet altijd maatwerk verrichten, terwijl elke…
Why this matters
AFM guidance on PEP (politically exposed persons) client due diligence procedures. Addresses AML/financial crime compliance with focus on risk-based approach, avoiding discrimination, proper definitions, outsourcing oversight, and staff training.
The escalation of the Middle East conflict leaves the global economy in a clearly worse state than previously expected. Higher inflation expectations, lower growth and heightened uncertainty are also affecting the financial sector, according to the annual Financial Stability Report from the Dutch Authority for the…
AFM-bestuursvoorzitter Laura van Geest verzorgde op 20 mei de keynote tijdens de AFME Sustainability Conference in Amsterdam.
Why this matters
This is a speech by AFM board chair at AFME Sustainability Conference emphasizing sustainability as economic necessity. It is informational/news content rather than regulatory requirement, hence null urgency.
Een gelijk speelveld, meer duidelijkheid voor marktpartijen, ruimte voor verantwoorde innovatie en een zorgvuldige bescherming van beleggers. Vanuit die visie wil de AFM zorgen voor meer duidelijkheid over beleggingsconcepten, waaronder automatisch herbalanceren en risicoafbouw binnen execution-only. De markt vroeg…
Why this matters
AFM announces regulatory clarification initiative on execution-only investment services, specifically addressing automatic rebalancing and lifecycle investing. This is informational guidance development with consultation expected Q3 2026.
Vanaf 11 oktober 2027 verkort de afwikkelingscyclus voor effectentransacties van T+2 naar T+1. Dit vraagt om aanpassingen in systemen en processen in de hele kapitaalmarktketen. Om de voortgang te monitoren, roept de Autoriteit Financiële Markten (AFM) marktpartijen op om twee T+1-gereedheidsenquêtes in te vullen. Het…
Why this matters
AFM announcement regarding T+1 settlement cycle transition (from T+2 to T+1 effective October 11, 2027). Calls for market participants to complete readiness surveys by June 9, 2026.
De Europese Anti-Witwasautoriteit (AMLA) heeft op 12 mei in een persbericht het definitieve eligibility reporting package gepubliceerd en kondigt aan dat zij extra data opvraagt via de nationale toezichthouders. Financiële ondernemingen onder Nederlands toezicht hoeven geen afzonderlijke rapportage volgens het…
Why this matters
AFM announcement clarifying that Dutch financial firms will not receive separate AMLA eligibility reporting requests, as requirements are integrated into existing questionnaires. This is informational guidance on regulatory implementation for anti-money laundering compliance under the new European AMLA framework.
On 12 November 2025, the Dutch Authority for the Financial Markets (AFM) issued an instruction to Euronext Amsterdam N.V. (Euronext) due to breach of the rules on providing access for central securities depositories (CSDs). Euronext complied with the instruction. European legislation requires trading venues to provide…
AI Analysis
AFM has issued and published an instruction against Euronext Amsterdam for breaching the **open access obligations under Article 53(1) of CSDR** by imposing restrictive conditions on CSDs’ access to its transaction feeds, linked to a new settlement model. Euronext has withdrawn the conditions and confirmed continued and new access for non‑linked CSDs, signalling that trading venues must ensure any changes to settlement models, default CSDs or connectivity rules do not directly or indirectly restrict non‑discriminatory, transparent CSD access.
Key dates
12 November 2025
- AFM issues an instruction to Euronext Amsterdam for breach of CSDR Article 53(1) open access rules and sets a period for remediation
13 May 2026
- AFM publishes the instruction decision after it becomes irrevocable and confirms that Euronext has remediated by withdrawing the restrictive conditions and confirming continued and new access for CSDs
Suggested considerations
Trading venues must review settlement models, CSD linkage arrangements and related policies to ensure that all conditions for CSD access to transaction feeds are non‑discriminatory, transparent, and fully aligned with Article 53(1) of CSDR.
Compliance and legal teams must identify and remove any contractual or operational provisions that directly or indirectly favour a linked or in‑house CSD over independent or alternative CSDs in terms of access to transaction feeds.
Trading venues must implement internal governance and change‑management controls to ensure that future settlement model changes, including the introduction of a preferred CSD, are subject to ex‑ante compliance review against CSDR open access obligations.
Market infrastructure firms must establish documented criteria and procedures for handling CSD access requests, ensuring these criteria are objective, transparent, and applied consistently to linked and non‑linked CSDs.
Compliance functions should conduct periodic audits of access arrangements, transaction feed connectivity, and any associated fees or technical requirements to confirm that no indirect barriers to CSD access exist.
What changed
- Trading venues subject to CSDR must ensure that access for central securities depositories to transaction feeds is provided on a non‑discriminatory and transparent basis as required by Article...
Conditions or criteria attached to the designation of an alternative CSD (other than a venue’s preferred or “linked” CSD) that have the effect of limiting access to transaction feeds are treated as a...
AFM has clarified, through enforcement, that settlement model changes and associated contractual or operational conditions are within the scope of supervisory scrutiny for compliance with CSDR open...
Euronext has withdrawn three announced conditions that restricted access for certain CSDs and has confirmed continued access for CSDs with existing connectivity to its transaction feeds.
Euronext has also confirmed access for other CSDs that requested access to act as alternative CSDs, establishing a practical expectation that trading venues respond positively to reasonable access...
Compliance impact
Non‑compliance with CSDR open access obligations can lead to formal instructions, ongoing supervisory monitoring, reputational damage through public enforcement decisions, and potentially further sanctions where breaches are not timely remediated. Given the centrality of CSD access to post‑trade infrastructure, persistent breaches may also trigger broader scrutiny of governance, conflicts of interest, and competition concerns.
Het convenant tussen de Autoriteit Financiële Markten (AFM) en Stichting DSI over de vakbekwaamheid van beleggingsprofessionals is een efficiënt en effectief instrument binnen het risicogestuurde toezicht van de AFM. Dat is de conclusie van de audit door onderzoeksbureau KWINK groep in opdracht van de AFM. Het…
Why this matters
AFM audit report on DSI covenant for professional competency requirements under MiFID II and Wft. Informational news about covenant effectiveness, renewal plans, and recommendations for improvement. Addresses professional qualification standards for investment professionals at regulated firms.
This is a general newsletter subscription announcement from AFM (Dutch financial regulator) emphasizing their commitment to fair markets and market conduct. It contains no specific regulatory requirements, deadlines, or actionable guidance. Classified as informational/promotional content with null urgency.
Around 800,000 Dutch households have sufficient financial resources to invest but do not do so, even though they may face financial shortfalls in the future. For this group, it may therefore be appropriate to allow their available assets to generate higher returns, in order to strengthen their future financial…
Why this matters
AFM press release on research findings regarding household investment barriers and opportunities. Focuses on consumer protection and conduct by promoting responsible investing while lowering barriers for non-investors. Informational content about regulatory commitment to sustainable financial well-being.
De Europese anti-witwas- en anti-terrorismefinanciering autoriteit (AMLA) is twee openbare consultaties gestart. De ontwerpinstrumenten geven richting aan hoe meldingsplichtige instellingen de risico’s op witwassen en terrorismefinanciering moeten identificeren, beoordelen en beheersen. Hiermee wordt gewerkt aan een…
Why this matters
AMLA launches public consultations on AML-CFT risk assessment guidelines and regulatory technical standards for group-wide minimum requirements. This is informational content announcing consultation periods (deadline May 8, 2026) affecting multiple financial sectors on anti-money laundering and counter-terrorism...
Financial institutions are working to make their digital services accessible. This is important, because it ensures that people with disabilities can manage their finances independently. To provide further guidance to the sector, the Autoriteit Financiële Markten (AFM) shares expectations and points of attention in…
AI Analysis
AFM’s third EAA update makes clear that Dutch financial institutions must not only fix accessibility gaps, but also **assign clear internal accountability**, **embed accessibility compliance in governance and monitoring**, and **submit more specific non-compliance notifications**. AFM also announced a **sector-wide compliance review in the coming months**, with a focus on whether websites meet WCAG criteria, especially **level A** requirements, so compliance teams should treat this as an active supervisory campaign rather than routine guidance.
Key dates
28 June 2025
- The European Accessibility Act came into force, and Dutch national measures began applying to covered new products and services
Coming months (TBD, est. late 2026) Deadline
- AFM will conduct an accessibility compliance review of the sector, focusing on WCAG compliance, especially level A criteria
23 April 2026 Deadline
- AFM published its third EAA update and announced a forthcoming sector compliance review
Suggested considerations
Firms should map all consumer-facing digital services and identify which websites, apps, and digital documents fall within EAA/WCAG scope.
Firms should assign a named internal owner for accessibility compliance, monitoring, remediation tracking, and regulatory notifications.
Firms should document accessibility risks and remediation plans for each in-scope digital service, including the precise pages, functions, or documents affected.
Firms should embed accessibility checks into design, development, testing, and change-management processes so compliance is monitored continuously.
Firms should review EAA non-compliance notifications and make them more specific, including the exact accessibility issues, affected locations, and remediation status.
What changed
- AFM expects financial institutions to identify accessibility risks in their digital services and implement improvements that meet the required WCAG criteria.
AFM expects firms to embed and monitor accessibility through internal processes, rather than treating accessibility as a one-off remediation project.
AFM is emphasizing clear accountability for safeguarding digital accessibility, which means firms should be able to show who owns accessibility compliance, monitoring, and remediation internally.
AFM says EAA notifications of non-compliance must be more specific, because current submissions often do not describe the exact accessibility issues or where they are located.
AFM has published further instructions on how to answer certain questions in the EAA notification form, indicating a stronger supervisory focus on the quality of regulatory reporting.
Compliance impact
The compliance risk is material because AFM is moving from guidance to active review and may directly challenge firms with shortcomings. In practice, poor documentation, vague notifications, or weak governance can expose firms to supervisory intervention, remediation orders, and escalating scrutiny over the accessibility of consumer-facing channels.
On 20 April 2026, the Dutch Authority for the Financial Markets (AFM) imposed an administrative fine of €297,000 on Arrowstreet Capital, Limited Partnership for the systematically incorrect notifications of its net short positions in two companies listed on Euronext Amsterdam. Arrowstreet thus violated the rules on…
AI Analysis
AFM has imposed an administrative fine of €297,000 on Arrowstreet Capital, LP for **systematic underreporting and underdisclosure of net short positions** in two Euronext Amsterdam issuers between July 2020 and November 2024, caused by an error in its short position calculation methodology. The case underscores that AFM expects robust calculation, control and reporting frameworks around short selling, and that repeated methodology errors leading to incorrect notifications and public disclosures will be treated as serious violations of the EU short selling and Dutch transparency regimes, even where firms later cooperate.
Key dates
July 2020
– Start of the period in which Arrowstreet’s incorrect calculation methodology led to systematically incorrect net short position notifications to AFM and underdisclosures to the public
November 2024
– End of the period during which Arrowstreet violated short selling rules through inaccurate notifications and disclosures of its net short positions in Just Eat Takeaway.com and Galapagos
20 April 2026
– AFM imposes an administrative fine of €297,000 on Arrowstreet Capital, LP for the systematic incorrect notifications and underdisclosures of net short positions
22 April 2026
– AFM publishes the enforcement notice stating that the case has been settled via a simplified procedure and is closed
Suggested considerations
Review and document the firm’s methodology for calculating net short positions in EU‑listed shares, ensuring alignment with the EU Short Selling Regulation and AFM’s thresholds and definitions, including aggregation rules and treatment of derivatives.
Perform a comprehensive back‑testing and reconciliation of historical and current net short position calculations against trade data, positions and corporate actions to identify any systemic discrepancies or underreporting risks.
Implement or enhance controls that validate short position calculations prior to submission, including independent second‑line checks, exception reporting, and automated variance checks for large movements or threshold breaches.
Map all AFM short selling notification and disclosure thresholds and timing requirements into the firm’s surveillance and reporting systems, ensuring automated alerts when positions reach, exceed or fall below relevant levels.
Establish robust governance over short selling reporting, including clear ownership between trading, operations, risk and compliance, formal sign‑off procedures, and regular reporting to senior management on short‑selling compliance.
What changed
- AFM has reaffirmed strict enforcement of notification and disclosure obligations for net short positions in shares admitted to trading on Euronext Amsterdam, including the expectation of accurate...
The case confirms AFM’s interpretation that systematic underreporting (wrong figures in 101 notifications) and underdisclosure to the public (wrong figures in 85 cases) constitutes a material breach...
AFM emphasises that net short positions must be notified promptly and accurately, and that disclosures above the public threshold are a key tool for market participants to understand negative...
AFM demonstrates that self‑reporting, prompt correction, full cooperation and remediation can result in a reduced fine and simplified settlement, signalling a clear incentive structure for firms to...
The publication reinforces that AFM will use the short selling register and underlying notifications to monitor for market abuse, market distortion and systemic risks, increasing scrutiny on firms...
Compliance impact
Non‑compliance with AFM short selling notification and disclosure obligations can result in significant administrative fines, reputational damage, and heightened supervisory scrutiny, particularly where errors are systemic or affect numerous notifications. AFM’s willingness to reduce the fine in this case was contingent on proactive self‑reporting and remediation, but the underlying violations still triggered a sizeable penalty and public enforcement notice.