The AFM has published its priorities and key supervisory activities for 2025. According to the regulator, the rise of new revenue models driven by digitalisation, geopolitical tensions, the growing sustainability market, and the financial sector’s vulnerability to cyberattacks are impactful trends affecting both the financial sector and the AFM.
Each year, the Agenda outlines key developments and sets out the main priorities and activities across different domains, including financial services, capital markets, asset management, accountancy, and financial reporting, as well as AFM-wide topics.
This domain focuses heavily on the products and services offered by providers and advisers, as well as supervision of the pension sector. In separate articles, we will take a closer look at the AFM’s priorities and supervisory activities for financial service providers and the pension sector.
Other key priorities include sustainability, risks associated with digitalisation, and supervision of crypto service providers. The AFM will conduct investigations into AI applications, compliance with the SFDR, sustainability claims, and the marketing and advertising practices of crypto providers. Additionally, it will take enforcement action against crypto providers and hire-purchase providers for sustainability projects if they operate without a licence.
The increasing digitalisation of markets and the risks of market abuse are the key priorities for capital market supervision. The AFM aims to contribute to resilient and fair European capital markets through investigations into IT risk management, supply chain dependencies and market power, digital resilience, and the risks associated with AI use.
Digital resilience and sustainability are also top priorities in the supervision of the asset management sector. The AFM will conduct investigations into AI applications, digital resilience, (model) risk management, data risk management, the sustainability performance of asset managers’ investments, and transparency requirements under the SFDR. Smaller investment firms will be assessed for compliance with regulations on product development, professional competence, and suitability.
Key priorities in this area include ESG reporting, strengthening corporate culture and improving quality, digitalisation, the market structure of accountancy firms, and detecting fraud risks. To support these efforts, the AFM will investigate the implementation of the CSRD, CSRD and ESRS reporting, exam fraud, the time and attention audit firms devote to statutory audits, remuneration structures at accountancy firms, fraud risk analysis by auditors, and the quality of financial reporting by listed companies.
Combating financial crime is a priority that applies to all market participants, with compliance with anti-money laundering and sanctions regulations being the central pillar. Through risk-based investigations into compliance with the Wwft and the Sanctions Act, the AFM aims to strengthen the gatekeeper role of market players. The regulator has also specifically stated that it will increase its focus on mortgage fraud.
The 2025 Agenda also reveals that the AFM’s organisational structure will shift to multidisciplinary teams in the summer of 2025. It appears that data and IT experts will be integrated into the various supervisory teams, whereas they were previously organised into specialist teams.
The AFM’s digital portal will also be updated in 2025. The new portal aims to improve security and standardise data exchange while reducing manual processes. However, it is not entirely clear from the explanation whether this reduction in manual work will also apply to market participants. Ideally, the AFM will take this opportunity to incorporate user feedback into the portal’s redesign.
The 2025 Agenda provides market participants with insight into the topics the AFM considers important. Businesses can use this information to help determine their own priorities, such as when drafting their annual compliance agenda.
Do you need help drafting a compliance agenda or annual plan? Our compliance specialists are happy to assist you. Learn more about our compliance services or contact us.
