Information session about fit and proper assessments DNB
On Tuesday 28th May from 3:00-4:45 PM CET DNB will organize an online information session about fit and proper assessments.
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Well begun is half done. This also holds true for proposing candidates for fit and proper assessments. It is important to submit all relevant information when submitting the application, enabling us to take it into consideration without delay. To guarantee that the information submitted is complete, we recommend that you use our most current template matrix. The forms and templates are available on this page.
There are various reasons for an assessment, and therefore we use the following online application forms:
The forms are available via Supervisory applications in My DNB.
A separate form is available for significant banks and their subsidiaries. To apply for an assessment, they must use the Prospective Appointment Notification Form for Banks that qualify as Significant Institution (under SSM-regulation). For more information, see: European law and SSM consequences and the IMAS Portal.
Depending on your application, you may need to upload additional documents. These are stated on the application form. If documents are missing, we will request them from you, and the time we need to consider your application will be longer. Below, we list the requirements for each document.
A legible copy of the candidate's valid passport or ID card (both sides) must be included with the application. Please note that we cannot accept a driver's licence as a valid ID. We plan to use citizen service numbers (BSN) for identification purposes in the future.
We use the copy of the ID document to verify the candidate's personal data, which is necessary to check judicial information. The document must be clearly legible and valid on the starting date of the new position. The photo, BSN and machine readable zone may be blacked out, as we do not need them to check judicial information. You may wish to consult the Dutch Government website for more information about safely making copies of identity documents (in Dutch only).
The candidate's CV must be complete and up-to-date, and it must include at least the following:
The job profile must list at least the following:
Please provide a description of the actual recruitment and selection procedure that was followed to recruit and select your candidate. Rather than attaching a standard procedure document, we would ask you to elaborate on the actual procedure followed.
Please provide a description of the decision-making process preceding your selection of the candidate, including your considerations as to why the candidate meets the job profile. Please also provide the outcomes of your own assessment on the propriety of the candidate. If the candidate does not fully meet the job profile and/or the propriety requirements, please state the reasons why this individual was nevertheless selected and what value he or she will add to the board. If relevant, you can describe the measures taken to counter any conflicts of interest or the semblance thereof.
The suitability matrix and accompanying notes provide insight into the candidate's expertise and capabilities and of those of the other board members. The composition of the board as a whole also plays a role in assessing a person’s fitness.
To be able to assess the matrix we need a description of at least the following:
In your explanation of the scores, it is important that you specify why the candidate and board members were a particular score, e.g. based on relevant education and experience.
Example 1: If a proposed supervisory board member has worked in the banking sector for several years in various positions, you obviously assign them a high score on "knowledge of products and services". However, if you assign a high score to someone who has worked in a different sector, you must provide adequate motivation.
Example 2: if a candidate is proposed as a member of the investment advisory committee of a pension fund, and has worked at an asset management company for a number of years or has completed a high-level business accounting course, a higher score on "financial aspects" is only logical. If the candidate has gained their asset management experience in another way, you must be able to substantiate this.
You must take account of the statutory maximum number of supervisory positions a management or supervisory board member is allowed to hold. This means that you must demonstrate that the candidate meets the requirements of the Management and Supervision Act (Wet bestuur en toezicht – Wbt) or, in the case of pension funds or occupational pension funds, the composition of the candidate's FTE score, as required under the Pension Fund Governance Reinforcement Act (Wet versterking bestuur pensioenfondsen). To guarantee that the information you submit is complete, we recommend that you use our pension funds FTE score template. You can this webpage for the format. If the candidate is to be appointed at a significant institution subject to SSM supervision, the CRD IV requirements apply.
Please also provide an indication of the candidate's actual time commitment. You can do so by stating the average weekly or monthly time commitment for each of the secondary positions in the candidate's CV. You may also provide a separate document, such as the time commitment statement often used by pension funds.
Based on the application file, we establish whether the candidate has the required expertise and experience, fits the job profile and adds value to the board as a whole. If this preliminary investigation presents us with a clear picture, we may issue a positive decision without having to interview the candidate.
A description of how the candidate has prepared for the position may help us form a comprehensive picture of their fitness. Examples of the candidate's activities include reading relevant documents, holding meetings or discussions with others within the organisation, attending meetings as an observer or participating in internal or external training programmes.
Referees must meet the following conditions:
Please provide the referees' names, contact details, current position and relationship to the person to be assessed. In view of privacy regulations, please do not provide us with any further contact details than requested.
We will not necessarily contact all referees. Please inform your referees that we might not contact them.
For a proposed appointment, the candidate must also complete the Propriety Assessment Form. If DNB or the AFM assessed the candidate's propriety less than three years ago and no changes to any relevant facts or circumstances have occurred since the previous assessment, there is no need to submit the form.
We advise candidates to always study the form in advance, as it explains what we mean by relevant facts, circumstances and antecedents, including examples.
You can add additional documents if you believe they provide us with a more comprehensive picture of the candidate or the position. Examples include a training or induction programme, assessment outcomes and management development assessments.
When signing an Initial Assessment Application Form in our Digital Supervision Portal, you must upload a signatory statement. This ensures that your application is signed by an authorised signatory of your institution. You will find the signatory statement in the Digital Supervision Portal.
As part of a propriety assessment, we check criminal records to determine whether the natural person has ever been involved in criminal acts that affect their propriety.
Since not all criminal offences are included in the Dutch judicial system, we will need a criminal records extract from some of the persons that are assessed for propriety in the context of a request for registration as a crypto service provider. A criminal records extract is a statement from a competent authority confirming that the person to be assessed has not committed any criminal offences that are relevant for the proposed position.
The following persons are required to submit a criminal records extract in the context of a propriety assessment:
The infographic below shows the situations in which a criminal records extract must be submitted:
Please note that persons who have resided in multiple countries outside the Netherlands during the past eight years may have to submit multiple criminal records extracts.
A criminal records extract is available from the competent authority in the relevant country of residence and must meet the following conditions.
Pension funds and premium pension institutions must substantiate the fitness of a board member who they propose to appoint to a key function in risk management or internal audit in the self-assessment form. This form can be downloaded at Forms & formats.
You will find more information (in Dutch only) on the fitness requirements for key function holders here.
On Tuesday 28th May from 3:00-4:45 PM CET DNB will organize an online information session about fit and proper assessments.
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