Update FATF-warning lists November 2026
05 November 2026
News item supervision
FATF released an update of its ‘grey’ and ‘black’ lists.
Read more Update FATF-warning lists November 2026Are institutions required to submit additional Tier 1 (AT1) instruments as referred to in Article 52 of the CRR and Tier 2 (T2) instruments as meant in Article 63 of the CRR for assessment to the supervisory authority before issuing them?
Published: 23 September 2015
No, prior assessment of capital instruments for qualification as AT1 or T2 capital is not required. This applies equally to significant institutions (SIs) under direct ECB supervision and to less significant institutions (LSIs) supervised by DNB in cooperation with the ECB.
Instruments may be assessed retrospectively, however. In some cases, the supervisory authority may conclude in retrospect that an institution has incorrectly designated an instrument as own funds, and consequently disqualify it as such.
However, we encourage institutions to apply for a preliminary assessment if they intend to issue a new or more complex AT1 or T2 instrument for the first time or in other exceptional circumstances. We encourage banks to apply for a preliminary assessment in such cases. SIs should contact their Joint Supervisory Team (JST) and LSIs should contact DNB for this purpose. In the case of non-complex or near-identical follow-up issuances, a notification that the transaction has been completed will suffice.
We want to emphasise that a preliminary assessment does not automatically result in formal approval from the supervisory authority, however, as the latter will only inform the institution that the instrument has been assessed, and - in case of a positive assessment - that there is no reason at that point to assume the instrument would not qualify as AT1 or T2 capital. The instrument may still be disqualified in retrospect, however. This also applies to near-identical follow-up issuances that have not been submitted for prior assessment.
If institutions wish to discuss an issuance with the supervisory authority in advance, they are advised to submit the following documentation to enable assessment as to whether the instrument may qualify as AT1 or T2 capital:
From a resolution perspective, the instrument should also comply with the requirements set by the competent resolution authority. Institutions are advised to contact the resolution authority if they intend to issue such an instrument.
05 November 2026
News item supervision
FATF released an update of its ‘grey’ and ‘black’ lists.
Read more Update FATF-warning lists November 2026
05 November 2026
26 October 2026
News item supervision
As of 23 October 2026, all application forms for fit and proper assessments will require applicants to provide invoice details for the assessment fee.
Read more Request for invoicing details for fit and proper assessments
26 October 2026
15 October 2026
News item supervision
The revised market risk capital requirements under the Fundamental Review of the Trading Book (FRTB) will become applicable on 1 January 2027. The European Commission (EC) and the European Banking Authority (EBA) have published further clarification on this matter.
Read more DNB calls on institutions to prepare in a timely manner for the introduction of FRTB on 1 January 2027
15 October 2026
12 October 2026
News item supervision
De Nederlandsche Bank (DNB) will organize a physical information session about fit and proper assessments on Thursday 5th November from 3:00-4:45 PM CET. Please note that this session will only be held in Dutch, you are of course welcome to ask your questions in English.
Read more Information session about fit and proper assessments DNB (November 2026)
12 October 2026
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