Supervisory fees

Datum 24 juli 2020

The Regulation on the Funding of Financial Supervision 2020 was published on 17 June 2020. In our previous newsletter, we discussed supervisory fees, but we have noticed that the exact cost structure is not fully clear to everyone involved. This is why we provide the overview below.

Fees for one-off supervisory actions

  • Fees for one-off supervisory actions are laid down in the Regulation on the funding of one-off supervisory actions (“the Regulation”).
  • If you are already operating as a service provider and apply for registration, you will not be charged separately for fit and proper assessments of board members. By contrast, if new board members are appointed after registration, or if board members change their position or remit within your organisation, they must be reassessed for fitness.
  • We charge a fee of EUR 5,000 for handling the application for registration, including assessments. Irrespective of the outcome, we send out the fee note following completion of the application procedure.
  • Without an application for registration, we charge the following fees for assessments:
    - fitness EUR 2,000
    - propriety EUR 1,100
    - As a rule, a crypto service provider’s board members must be assessed for both fitness and propriety (EUR 3,100 in total).
  • A fitness assessment (EUR 2,000) generally suffices if they were assessed for propriety by DNB or the AFM before and no changes have occurred since.
  • Any holders of a qualifying holding must only be assessed for propriety (EUR 1,100). 

Fees for regular, ongoing supervision in 2020: approximately EUR 18,000

This means we do not have any data on their revenue for 2019, so we cannot allocate supervisory fees in accordance with their ability to pay. For this reason, we charge only a base amount, which is relatively high, to all crypto service providers in 2020. It is as yet unclear how many parties will become subject to our supervision in 2020. Even so, base amounts should not be unnecessarily high. This is why we considered the bandwidth of expected crypto service providers and assumed a relatively large number within that bandwidth. If fewer parties should become subject to our supervision in 2020, thereby creating a deficit, this must be settled in 2021. In that year, fees can be allocated in accordance with the ability to pay.

  • Pro-rated amounts:The base amount of EUR 29,850 referred to in the Regulation will be substantially lower in actual effect. The amount is an annual fee, whereas the applicable legislation only took effect on 21 May 2020. Most parties have been subject to supervision since that date. Their fee must be calculated pro rata to the part of the year during which they are subject to supervision. For those parties, the amount will be just over EUR 18,000.
  • Definitive fee note for 2020: We will be sending out the fee notes for our regular supervision in 2020 in the fourth quarter of 2020. 

Supervisory fees in 2021

Please refer to this Open Book on Supervision page for more information.

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