DNO for shareholdings (Section 3:95 of the Wft)
When acquiring or increasing a qualifying holding in a financial undertaking, you need prior approval from De Nederlandsche Bank (DNB) or, in the case of a bank, the European Central Bank (ECB). In brief, a qualifying holding consists of a holding of 10% or more in the form of a capital interest, voting rights or comparable control.
Published: 19 July 2017
Latest update: 22 September 2026
If you plan to acquire or expand a qualifying holding in the following financial institutions, you need a declaration of no-objection (DNO):
Settlement agent
Bank
Manager of an undertaking for collective investment in transferable securities (UCITS)
Investment firm
Electronic money institution
Special purpose reinsurance vehicle
Financial institution with a certificate of supervised status
Defined contribution pension institution
Insurance or re-insurance company
Payment institution
Our Open Book pages on market access will give you more information on these different types of institutions.
Risk-based assessment
DNB assesses applications for a DNO, as referred to in Section 3:95(1) of the Financial Supervision Act (Wet op het financieel toezicht – Wft), on a risk-based basis.
Under this risk-based supervisory approach, DNB first determines the risk level of the DNO applications submitted to it. Where an application has a low-risk profile, only a limited substantive assessment is carried out. In such cases, shortly after the completeness of the application has been established, DNB informs the applicant that a positive decision will follow. Where an application does not have a low-risk profile, the DNO application is assessed, in whole or in part, on its substance.
Through this supervisory approach, DNB aims to ensure that applicants submitting a straightforward, low-risk DNO application receive a response more quickly. This approach applies to applications on which DNB takes a decision.
Information Declaration of no-objection
Definition of qualifying holding
General information
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