Please note: this article is tailored to the Dutch market.
The AFM has published its priorities and key supervisory activities for 2025.
The regulator notes that the emergence of new revenue models due to digitalisation, the growing market for sustainability, and the financial sector’s vulnerability to cyberattacks are significant trends impacting both the sector and the AFM itself.
The AFM views financial advisers as key players in the transitions towards sustainability, digitalisation, and pensions. It has announced plans to make greater use of data in supervising financial service providers.
Most of the AFM’s key activities for 2025 are a continuation of previous supervisory efforts. Concerns previously raised regarding compliance with requirements for controlled and ethical business operations, as well as the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), are set to remain prominent in 2025.
This year, the AFM will continue its investigation into the quality of mortgage advice. Based on the 2025 Agenda, this will primarily involve discussions and risk-driven assessments of advisory quality. For now, a market-wide investigation does not seem to be on the cards. However, the AFM will update its guidance on mortgage advice.
Financial service providers that have recently obtained their licences may be subject to checks to assess whether they meet market entry requirements in practice. Additionally, the AFM will examine whether financial service providers continue to comply with quality standards and the requirements for controlled and ethical business operations.
It is also encouraging to note that licence applications are once again expected to be processed within statutory timeframes. Over the past year, we observed that this often posed a challenge when assisting our clients.
Compliance with the Wwft and Sanctions Act remains a key priority for the AFM across all sectors. In line with this, the AFM has announced increased efforts in tackling mortgage fraud, including further investigations.
We advise financial service providers to review whether their Wwft policies still meet current requirements and to ensure their operational practices align with these policies. The AFM’s Market Monitor from last year highlighted that there is still significant work to be done. Regular knowledge updates are also essential for policymakers and employees. Those responsible for Wwft compliance must undergo periodic training. An online, practice-oriented Wwft Awareness training course provides a convenient way for financial service providers to keep their knowledge up to date.
As part of its ongoing supervision of the product approval process, the AFM will conduct an investigation into third-pillar pension products and supplementary health insurance policies.
Third-pillar pension products represent a clear growth market. The AFM has previously shown interest in this sector. A 2023 report identified the limited uptake of these pension schemes as a concern—an unusual trigger for an investigation. The report called on the sector to lower barriers and improve awareness, comparability, and accessibility. It is expected that the upcoming investigation will place greater emphasis on customer interests.
An investigation will be conducted into the risks associated with the automation of acceptance processes in the mortgage chain. The AFM has long been concerned about the potential impact of errors when using source data for responsible lending decisions. The study aims to result in a publication outlining the necessary safeguards to ensure that customer interests are not compromised.
The principles for IT change management, published by the AFM last year, will also be assessed through an evaluation of credit providers.
Several investigations will focus on specific risks associated with certain products, such as third-pillar pensions and credit. Given the outlined approach, these studies are likely to result in general publications with recommendations.
Certain topics have been prioritised due to previous concerns. It is expected that further risk-based investigations will be carried out in these areas, potentially leading to enforcement measures.
It is wise to assess whether your business fully complies with current requirements in the priority areas relevant to you. This will help you avoid any unexpected issues if the AFM selects your company for an investigation.
Need support in understanding the applicable requirements or ensuring compliance? Our consultants are happy to assist, feel free to reach out.
