Each year, financial service providers receive a questionnaire from the AFM: the Market Monitor. The AFM has recently sent a letter regarding this to all financial service providers. The questionnaire is made available via the AFM portal. Firms are given four weeks to complete the questionnaire.
To ensure a more balanced distribution, the AFM has divided firms into three groups with different starting dates. Each group has four weeks from its designated start date to complete the questionnaire.
The most important section of the questionnaire consists of general (quantitative) data about the firm. Completion of the questionnaire is mandatory. Failure to submit it may result in enforcement action. Recently, the AFM revoked a licence from a financial service provider partly due to non-compliance with such information requests.
The data collected through the Market Monitor feeds into the AFM’s risk-based supervision. The annual levy for ongoing supervision is determined based on the reported turnover of a firm, and is partly based on actual revenue achieved.
The Market Monitor includes questions on outsourcing. Regulations expected to come into force from January 2026 will introduce specific requirements regarding outsourced activities. Financial service providers will be expected to maintain a register of outsourced tasks. All agreements related to outsourcing must be formalised in a contract, which must meet certain standards.
The questionnaire asks financial service providers what control measures they have implemented with regard to outsourcing. If you have contracts in place for outsourcing services, we recommend checking whether these agreements include the relevant topics mentioned when answering the related questions.
Additionally, a few questions are included about information security. This year, new European rules (DORA) have come into effect for larger financial service providers. The AFM also advises smaller firms not subject to DORA to take steps to enhance their digital resilience.
A policymaker within the firm must sign the questionnaire. According to the regulator, the questionnaire must be completed to the best of one’s ability, but the policymaker must declare, upon signing, that the information provided is complete, accurate, and truthful. Incorrect completion may lead to a regulatory incident and affect the assessment of policymakers.
If you have any questions about the Market Monitor or would like more information on information security, please feel free to contact us.
