Second-tier senior officers: suitability requirements

Factsheet

Banks and insurers themselves decide whether the managers among their second-tier senior officers are suited to their positions. Suitability implies that these managers display sufficient knowledge, skills and professional behaviour to properly perform their duties. Institutions are expected to draft a suitability assessment for all managers they screen.

Published: 04 March 2016

Disclaimer

This DNB policy statement is currently under review in light of Directive (EU) 2024/1619 (Capital Requirements Directive; CRD6), which is expected to enter into force for credit institutions in mid-2026. This policy statement will be amended accordingly. With the introduction of the new Article 91a CRD6, the concept of the second tier senior officers for credit institutions will be replaced by the term “key function holder.” Until the revision is finalized, this policy statement remains applicable.

Suitability assessment

Second-tier senior officers are assessed on the basis of their job profiles, and it should take no more than one sheet of paper to describe why they are suitable for their position. The assessment should demonstrate that they have the knowledge, experience and competences described in the profile, as well as that they fit in with the institution’s situation. The suitability assessment does not need to be sent to DNB.

Screening by DNB

We may check the process set-up at the institution as well as perform sample tests to check the quality of its assessment. In some cases we may decide to perform our own suitability screening.