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Declarations of no-objection (DNOs) for group companies


If multiple applicants of DNOs are part of the same group of companies, DNB may, upon request, decide to issue DNOs for group companies. In that case, DNB assesses the separate DNO applications jointly and combines the assessments where possible.

Published: 18 April 2019

This applies to DNO applications for group companies acquiring or increasing a direct or indirect qualifying holding in the same financial target enterprise, as meant in Section 3:95(1) of the Financial Supervision Act (Wet op het financieel toezicht – Wft). Please note, however, that the European Central Bank decides on DNO applications (including DNOs for group companies) concerning qualifying holdings in a bank. Each of the group companies involved must submit an application. DNB also assesses changes in the control chain of group companies. In many cases, such changes will require a DNO. We therefore recommend that you notify us of any changes well in advance.


DNOs for group companies may be issued if the companies acquiring or increasing a qualifying holding are part of a group of companies organisationally controlled by a single, central managing entity. DNB assesses the applications of every group company acquiring or increasing a direct or indirect qualifying holding (see the Joint Guidelines of EBA, EIOPA and ESMA on the prudential assessment of acquisitions and increases of qualifying holdings in the financial sector (JC/GL/2016/01)).

Since the individual companies are organisationally controlled under a single managing entity, their applications will be assessed jointly and, where possible, in a combined assessment procedure. Consequently, for certain details in the application it will be sufficient to refer to the common details provided by the top holding company or one of the other group companies involved, e.g. a joint business plan.

If you consider applying for DNOs for group companies, please contact DNB first.


Once the DNOs for group companies have been issued, you should notify DNB well in advance of any proposed changes to the control chain.

This includes changes that cause a group company to acquire or increase a qualifying holding in a financial enterprise. In such a situation, Joint Guidelines prescribe an assessment of the new link in the control chain. A change to a group company holding a direct qualifying holding in a financial enterprise within the existing group structure will always require a DNO application.

Other changes that must be reported to DNB in advance include transfers between group companies of indirect qualifying holdings or simplifications of the control structure that involve the removal of one or more links from the control chain.

Reporting changes

Changes can be reported by the group company in question or by one of the other companies of the group, such as the top holding company.

You can report changes by submitting the digital ‘DNO notification form for group companies’ in My DNB Supervision Services.

Existing DNOs

Changes to the control chain do not affect the legal effect of previously issued DNOs for group companies. However, changes mentioned above must always be reported.

Information Declaration of no-objection

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