Application of Joint Guidelines on declarations of no-objection

Datum 30 april 2019

The revised European Joint Guidelines have implications for DNB's assessment of applications for declarations of no-objection (DNOs).

The changes have an impact on the assessment of the reputation of a proposed acquirer of a DNO, the assessment of DNO applications for group companies and the calculation method for indirect qualifying holdings. Read more about these topics below.

Assessment of the reputation of a proposed DNO acquirer

We already assess proposed DNO acquirers for propriety. As of 1 July 2019, we will also assess their reputation as part of the application process. In addition to the propriety assessment, we also assess candidates’ management competence and technical competence. Want to find out more? See the Open Book on Supervision.

Assessment of DNO applications for group companies

From now on, we will assess all group companies in the control chain when considering applications for group DNOs. Proposed changes to the control chain must be reported to us well in advance, since in many cases they require a DNO. You can report such changes through a notification form, which will be made available in the Digital Supervision Portal soon. Until then you can report changes by sending an email to

See our website for more information about DNOs for group companies. Any questions? Then please contact us at

Calculation method for indirect qualifying holdings

In addition to acquiring direct qualifying holdings in a financial target company, it is also possible to acquire indirect significant influence in a financial target company. This refers to indirect participating interests of 10% or more, and this requires a DNO. We assess whether the acquisition involves significant influence and apply the calculation method as specified in the Joint Guidelines. See Open Book for more information about the calculation method, and about the control and the multiplication factor criterion in particular.