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04 April 2019 Supervision Supervision label Factsheet

Initial assessment – reputation assessment

When assessing someone's reputation, De Nederlandsche Bank (DNB) evaluates a natural person's propriety and professional competence.

We conduct a reputation assessment if a natural person acquires or increases a qualifying holding in a financial enterprise which requires us to issue a declaration of no-objection (DNO). DNB assesses the reputation of the day-to-day policymakers of the legal entity requesting the DNO.


We perform reputation assessments based on the information provided by the natural person to be assessed, and our review of that information. A reputation assessment not only involves an evaluation of a person's propriety but also of someone's professional competence. We make a further distinction between management competence and technical competence.

Professional competence

Management competence largely depends on experience in acquiring and managing holdings, and the careful consideration observed in the process. Technical competence is mostly evident through experience in leading a financial enterprise as a majority shareholder or as someone who has effectively managed a financial enterprise. The experience must also show proof of exercising due care.

Other than with propriety, the assessment of professional competence will take into account the level of influence of the DNO applicant in the financial enterprise.

European regulations

The reputation assessment is based on European regulations aimed at harmonising the assessment of acquisitions and increases of qualifying holdings in the financial sector.


  • Banks
  • Clearing & Settlement Systems
  • Clearing institutions
  • Collective investment schemes
  • Electronic money institutions
  • Exchange transaction
  • Insurers
  • Investment firms
  • Payment institutions
  • Pension funds
  • Premium Pension institutions
  • Trust offices