Consultation on amending the Regulation on Specific Provisions CRD and CRR in connection with the application of revaluation limits for covered bonds

Supervision consultation

Collateral assets in the cover pool of covered bonds may still be valued based on market value and mortgage lending value (as recently clarified by the EBA1). Previously, market value and/or mortgage lending value already served as the basis, but with the entry into force of CRR3, the prudential ‘property value’ applies as the new standard. 

Published: 11 November 2025

Supervision consultation Open

This is an open Supervision consultation. You can respond until 23 December 2025.

Although CRR3 has revised the valuation framework for collateral assets, valuation based on market value or mortgage lending value remains consistent with the Covered Bond Directive (CBD) and with Article 40h of the Prudential Rules Decree (Bpr) under the Financial Supervision Act (Wft). For Dutch issuers, switching to property valuation is therefore not currently mandatory for collateral assets in the cover pool of covered bonds.

Under Article 129(3) of the CRR, the regulations allow competent authorities to grant exemptions from the application of limits on the revaluation of real estate when using market valuation or mortgage lending value. DNB makes use of this supervisory discretion and has formally established this in a draft supervisory regulation. This ensures that the current market practice in the Netherlands remains in place.

Consultation and Publication

The draft supervisory regulation is being offered for consultation to the sector. After consultation, the final regulation, including explanatory notes, will be published in the Government Gazette (Staatscourant). The sector will be informed about the consultation and publication of the regulation through this explanatory note and a press release.

Respond?

You can respond until 23rd of December. Responses on this consultation can be submitted through the consultation form. If you give us your written consent, we will publish your consultation response including your name and/or function. Without your written consent, we will only publish the content of your reaction and, where applicable, the name of your organisation. Thus without your name and/or function. You can revoke your consent at any time by e-mailing consultatie@dnb.nl though it does not alter the legality of the publication of your name and/or function in the period leading up to the moment that the consent has been revoked.

For further questions you can reach out to consultatie@dnb.nl

For more information regarding the processing of your personal data by DNB and your rights under the GDPR please view our privacy note.

Adoption and publication of policy statement

After receipt, weighing and processing of the consultation responses DNB will decide on the adoption and publication of the final version of the consulted policy statement. DNB will communicate on the outcomes of this consultation through dnb.nl, including a feedback statement in which DNB (on an aggregated level) responds to the consultation responses. DNB will publish the content of the consultation responses on the website of DNB and where applicable including the name of the organisation. In case written consent is given, DNB shall publish the consultation responses including name and/or function.

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Consultatieversie wijziging Regeling specifieke bepalingen CRD en CRR vanwege de toepassing herwaarderingslimieten voor gedekte obligaties

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