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European law and SSM consequences


Published: 12 July 2023

Since the start of Europe’s single supervisory mechanism (SSM), the ECB also has a part to play in assessing the integrity and suitability of directors and members of the internal supervisory bodies at banks. In fact, it is the ECB that makes the final decision about suitability and integrity when it comes to significant banks, whereas its role will depend on the circumstances where non-significant banks are concerned.

Digitaal Portal SSM

As of 27 January 2021 all the Significant banks have to use the Digital Portal from the SSM (IMAS-Portal). We request that you submit per person one application into the IMAS-Portal, the same way as you were used to do in the Digital Supervision Portal (Digitaal Loket Toezicht) and not to use the option in the IMAS-Portal to submit multiple assessments as one application. Multiple persons in one application makes the handling on the DNB side more complex, a single submission ensures rapid processing of the assessment application.

Only reappointments and 2e echelon functions (except those that are seen as Key function holders) have to be submitted via the Digitaal loket toezicht. Link to the IMAS-Portal

Information on how the portal works is also available via this link.

Significant institutions

DNB will process the application, advise the ECB and agree the next steps, while observing national rules on timelines and procedures.

In consultation with the relevant ECB divisions and the Joint Supervisory Team, DNB will prepare a draft decision. This is then put to the ECB for decision-making.

The ECB’s decision will either be communicated by DNB’s Expert Centre on Fit and Proper Testing or by the ECB itself.

Impact of ECB involvement and further implementation of European procedures

ECB involvement may mean that the decision-making process is extended and that, if nominees are invited to an interview, ECB officers may sit in. These meetings will typically be held in the Netherlands but may take place in Frankfurt if parties agree. These interviews will, in principle, be conducted in English.

The ECB is strengthening its screening processes and procedures, and is expected to communicate further information in the course of 2016.

Non-significant banks

These types of institution will submit their applications to DNB, with DNB also making the final decision. In special circumstances the ECB may be involved in the decision-making process.

Second-tier senior officers

Screening of applications for second-tier senior officers at both significant and non-significant banks will be handled by DNB.