Banking & Credit in Netherlands

Key dates

2026-12-07 Deadline

First phased requirements under the amended RTS on settlement discipline and related ESMA guidelines apply to allocations and confirmations, including electronic, standardised and machine-readable communications, subject to the temporary technical disruption exception.

2027-07-01 Deadline

Additional phased requirements under the amended RTS on settlement discipline become applicable, as specified in the regulation’s transitional provisions.

2027-10-11 Deadline

Regulation (EU) 2025/2075 applies and the EU standard securities settlement cycle changes from T+2 to T+1; the final phase of related settlement-layer requirements also applies.

Suggested considerations

• Firms should map every affected transaction type, market, currency, venue, CSD, custodian, broker, client and outsourcing provider across the full trading and settlement ecosystem rather than assessing only internal readiness.
• Compliance and operations teams may wish to confirm whether allocations and confirmations can be completed on trade date and transmitted through electronic, standardised and machine-readable channels from 7 December 2026, including accurate place-of-settlement data where required.
• Firms should assess and test ISO or other applicable international messaging standards, matching platforms, standing settlement instruction governance, exception handling and the documented process for temporary technical disruptions.
• Firms should identify manual processing steps that cannot reliably operate within the shortened timetable and consider automation, straight-through processing, reconciliation, controls over data quality and resilient fallback arrangements.
• Firms should obtain implementation commitments and test plans from clients, brokers, custodians, CSD participants, CSDs, CCPs, vendors and outsourcing providers, with evidence of end-to-end testing and defect remediation.
• Firms should review liquidity, collateral, margin, FX funding, corporate-action, securities-lending, fund dealing and investment-operation processes for the reduced interval between trade and settlement.
• Firms should maintain a regulatory change plan covering the phased milestones on 7 December 2026, 1 July 2027 and 11 October 2027, with senior management oversight, documented risk acceptance and escalation of unresolved dependencies.

What changed

Regulation (EU) 2025/2075 amends Regulation (EU) No 909/2014 (CSDR) and provides for the EU settlement cycle to apply on a T+1 basis from 11 October 2027. Commission Delegated Regulation (EU) 2026/1536 amends the RTS on settlement discipline in Commission Delegated Regulation (EU) 2018/1229, with phased application beginning on 7 December 2026. From 7 December 2026, the allocation and confirmation process must use electronic, standardised communication channels and international messaging standards, with machine-readable communications required except during temporary technical disruptions.

Key dates

2024-02-28

Directive (EU) 2024/825 was adopted, amending the Unfair Commercial Practices Directive and the Consumer Rights Directive.

2026-03-27 Deadline

EU Member States were required to adopt and publish national transposition measures.

2026-06-24

The Dutch Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten was published in the Staatsblad, according to the AFM publication.

2026-07-16

The Dutch implementation legislation entered into force, according to the AFM publication.

2026-09-27

The ECGT rules became applicable to consumer-facing commercial communications across the EU, including relevant financial-services marketing; the regime is applicable as at the publication date of 2026-10-09.

Suggested considerations

• Compliance teams may wish to inventory all consumer-facing sustainability claims, labels and environmental references used in websites, fund marketing, advertisements, product names, brochures, social media, sales scripts and corporate marketing.
• Firms should consider mapping each claim to the specific product, service, activity or business component to avoid implying whole-product or whole-enterprise sustainability where the evidence covers only part of the offering.
• Firms should consider maintaining an evidence file for every material claim, including the scope of the claim, methodology, data sources, verification, assumptions, limitations and approval owner.
• Marketing and product-governance reviews may wish to identify generic terms such as green, sustainable, environmentally friendly, climate positive and eco-friendly and confirm whether the required recognised excellent environmental performance can be demonstrated.
• Firms should consider removing or rewriting claims that describe products or services as climate neutral, carbon neutral or having reduced climate impact where the claim depends solely or materially on offsetting emissions, and should distinguish mitigation from compensation.
• Compliance teams may wish to review all sustainability labels, badges and proprietary ESG marks and confirm that each is supported by an eligible certification scheme or public scheme with appropriate independent verification.
• Firms communicating net-zero, climate-neutrality or other future environmental objectives should consider documenting a detailed and realistic implementation plan with measurable interim targets, deadlines, governance, monitoring and evidence of progress.
• Firms should consider testing claims against both the ECGT/BW 6 requirements and applicable Wft, SFDR, MiFID II, IDD and other sectoral disclosure and conduct standards, because satisfying a sectoral disclosure rule does not cure a claim prohibited under the consumer-law framework.

What changed

The Dutch Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten amended Book 6 of the Dutch Civil Code, including the rules on unfair commercial practices in Articles 6:193a et seq., to implement Directive (EU) 2024/825, which amends Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights. For consumer-facing commercial communications, sustainability claims should be specific, accurate, verifiable and supported by appropriate evidence.

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...

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.