Reassessment: only where reasonably justified

Date 31 May 2012

Reassessments will only be carried out in response to new antecedents or doubts concerning competence or reliability. All reassessed officers will be entitled to examine the information gathered about them.


Experience shows that reassessments raise many questions. The supervisory authorities DNB/AFM abide by the rule that reassessment must be based on ‘reasonable grounds’. However, they do not have a ready-made list of such grounds, which can be many and varied. But there is one common denominator: there must be doubts concerning the actions of a particular individual or developments within a bank.

For example, doubts may arise concerning the competence of an individual due to customer complaints relating to inadequate service or concerns about changes in corporate culture. Such doubts could provide reasonable justification for a reassessment of that individual’s competence. Reassessment of the reliability of an institution could be triggered by various indicators, such as reports from the police or the judicial authorities.

As part of the reassessment, the supervisory authority will always conduct an interview with the individual concerned. This may result in that individual no longer being considered c and/or reliable and being asked to relinquish his/her post.


When conducting a reassessment, the supervisory authority will look at antecedents relating to criminal, financial and tax law, as well as supervision antecedents or measures that have been imposed by DNB/AFM, such as an injunction or fine. DNB and AFM will register all the antecedents of individuals in a new system known as the senior executives monitor. This system provides a total picture of an individual’s antecedents: this is vital for (re)assessing the reliability and/or competence of executive and/or non-executive board members.

Right to inspect one's file

Antecedents can be retained for up to 10 years. The processing of personal information is governed by prevailing personal privacy protection laws. All individuals can ask to view their own file. To do so, they should apply to the AFM’s Privacy Department and/or to DNB’s Compliance and Integrity Department.

Tip: Also read the article Improving assessment of competence and reliability in this Newsletter.

More information?

For more information about the senior executives monitor and assessments, visit this link