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Fit and proper assessments

Assessment of management board members, (co-)policymakers, supervisory board members and holders of a qualifying holding for crypto service providers.

As of the entry into force of the Act Implementing Amendments to the Fourth Anti-Money Laundering Directive, crypto service providers are required to apply for registration. DNB's supervision aims to safeguard ethical crypto services, and the assessment procedure is an important part of this. Management board members, (co-)policymakers, supervisory board members and holders of a qualifying holding (shares representing 10% or more of shares and/or voting rights), are essential to the corporate culture and therefore also to the integrity of a business.

Fit and proper assessment of individuals is compulsory under the following two scenarios:

  1. Initial assessment:

An initial fit and proper assessment takes place in the event of the proposed appointment of a management board member, (co-)policymaker, supervisory board member and holder of a qualifying holding. In the event of an initial assessment, an appointee may only take up the position after receiving a favourable decision as to their fitness, propriety, or both. In the case of requests for registration, the following applies:

    • As part of the registration process, all management board members, (co-)policymakers and supervisory board members must be assessed for fitness and propriety, while the holders of qualifying holdings (shares representing 10% or more of shares and/or voting rights) need to be assessed for propriety.
    • For existing crypto service providers that have submitted a request for registration when the Act enters into force, the persons subject to assessment may perform their functions during the transitional period.
    • DNB assesses whether someone is fit for a certain position within an organisation. The nature, scale and complexity of the organisations may vary. For this reason, DNB cannot determine the fitness of an individual without the organisation having first submitted a (draft) request for registration. We would therefore like to receive a (draft) request for registration prior to the assessment forms.
  1. Change in position:

A fitness assessment is position-specific, meaning that a fitness assessment is conducted for each proposed appointment. This also applies to policymakers within an organisation who have already been assessed and who have been given a different position or a different remit. Every change in position or remit should be reported to DNB.

Propriety assessment

DNB verifies whether the propriety of a candidate is beyond doubt, which involves ensuring their intentions, actions and antecedents do not stand in the way of performing their duties. In this respect, DNB primarily focuses on their antecedents (further information on the propriety assessments can be found here).

The fitness assessment

When assessing fitness, we determine whether a candidate has sufficient relevant knowledge and skills, and displays the required professional behaviour to perform the job. We determine this based on their education, work experience and competencies.

A fitness assessment is position-specific, which means a fitness assessment is carried out for every proposed appointment of a management board member, (co)policymaker and supervisory board member.

Policy Rule on Suitability

We assess an individual's fitness on the basis of the Policy Rule on Suitability. Fitness assessments of policymakers and co-policymakers of crypto service providers will be described in category A of the Policy Rule.


In exceptional circumstances we may decide to assess an incumbent management, co-policymaker, supervisory board member or holder of a qualifying holding for fitness, propriety, or both. Such a reassessment only takes place if facts or circumstances arise that provide grounds for revisiting a previous assessment. 


In order to apply for a fitness or propriety assessment, please use the the online form ‘Initial assessment crypto service providers’ in Supervisory applications within My DNB. We will not process any applications for assessment submitted without a request for registration.

We have also provided a YouTube animation (English subtitles available) and a short brochure to inform management and supervisory board members about the practical aspects of initial assessments.


Do you have any question about providing crypto services? Please email us at: toetsing.cryptos@dnb.nl.

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