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.