Financial institutions often serve many different customers in many different sectors, including customers in sectors with higher inherent integrity risks. The sector in which a customer operates is one of the factors that a financial institution...Read more
Documents to be submitted
Well begun is half done. This also holds true for proposing candidates for fit and proper assessments. It is important to submit all relevant information when submitting the application, enabling us to take it into consideration without delay. To guarantee that the information submitted is complete, we recommend that you use our most current template matrix. The forms and templates are available on this page.
There are various reasons for an assessment, and therefore we use the following online application forms:
- Application for an (initial) assessment related to a licence: you must use this form to apply for a fitness assessment, a propriety assessment or both. Such an assessment takes place when a supervised financial institution proposes to appoint a management or supervisory board member.
- Application form for an initial assessment of a second-tier senior officer. Bank and insurance managers reporting directly to the management board and responsible for activities with a potentially material impact on the institution’s risk profile must also be assessed for fitness and propriety. They are referred to as second-tier senior officers.
- Application for an (initial) fit and proper assessment in the context of registration as a crypto service provider: you must use this form to apply for an initial assessment of a management or supervisory board member, or a management board member of an institution with a qualifying holding in a crypto service provider.
- Application for a change in position or remit: you can use this form to report a change in position or remit. A change in position or remit means
an incumbent management or supervisory board member takes on a new position or assumes other responsibilities.
- Application for an initial assessment of an ultimate beneficial owner: you must use this form to apply for an assessment of the ultimate beneficial owner (UBO) of one of the following types of institution:
- an exchange institution having its registered office in the Netherlands,
- a trust office having its registered office in the Netherlands
- a provider of exchange services between virtual and fiat currency or a custodian wallet provider (crypto service provider)
- Application for an initial assessment related to a declaration of no-objection: you must use this form to apply for an assessment in the context of:
- a declaration of no-objection (DNO) as meant in Section 3:95 of the Financial Supervision Act (Wet op het financieel toezicht – Wft). A separate form is available to apply for the actual DNO.
- the appointment of a new management board member at a DNO holder.
- Reappointments notification form: you must use this form to notify us of the reappointment of a previously assessed incumbent management or supervisory board member whose position or remit within the organisation does not change.
The forms are available in the Digital Supervision Portal (DLT).
Application form for significant banks
A separate form is available for significant banks and their subsidiaries. To apply for an assessment, they must use the Prospective Appointment Notification Form for Banks that qualify as Significant Institution (under SSM-regulation). For more information, see: European law and SSM consequences and the IMAS Portal.
Documents to be uploaded
Depending on your application, you may need to upload additional documents. These are stated on the application form. If documents are missing, we will request them from you, and the time we need to consider your application will be longer. Below, we list the requirements for each document.
A legible copy of the candidate's valid passport or ID card (both sides) must be included with the application. Please note that we cannot accept a driver's licence as a valid ID. We plan to use citizen service numbers (BSN) for identification purposes in the future.
We use the copy of the ID document to verify the candidate's personal data, which is necessary to check judicial information. The document must be clearly legible and valid on the starting date of the new position. The photo, BSN and machine readable zone may be blacked out, as we do not need them to check judicial information. You may wish to consult the Dutch Government website for more information about safely making copies of identity documents (in Dutch only).
The candidate's CV must be complete and up-to-date, and it must include at least the following:
- Education and relevant training courses, stating the name and location of the education institute, years of attendance and diplomas/certificates obtained.
- Professional experience, including the statutory name and place of the institution, the period of employment, the position held, details of the duties and responsibilities held and the number of staff under the appointee's responsibility
- All secondary positions, stating:
- the statutory name and place of the institution
- the field of expertise or committee
- average weekly or monthly time spent on each secondary position
- any remuneration received
The job profile must list at least the following:
- fields of expertise
- duties and responsibilities
- expected time commitment
- required competences
- requirements in terms of education and experience
- in the case of a proposed management board member of an institution governed by the Wft: an organisation chart or other document showing the candidate's span of control
Description of the recruitment and selection procedure
Please provide a description of the actual recruitment and selection procedure that was followed to recruit and select your candidate. Rather than attaching a standard procedure document, we would ask you to elaborate on the actual procedure followed.
Description of decision-making and appointment considerations
Please provide a description of the decision-making process preceding your selection of the candidate, including your considerations as to why the candidate meets the job profile. If the candidate does not fully meet the job profile, please state the reasons why this individual was nevertheless selected and what value he or she will add to the board. If relevant, you can describe the measures taken to counter any conflicts of interest or the semblance thereof.
The suitability matrix and accompanying notes provide insight into the candidate's expertise and capabilities and of those of the other board members. The composition of the board as a whole also plays a role in assessing a person’s fitness.
To be able to assess the matrix we need a description of at least the following:
- A description of how the matrix was composed,
For example, how the scores were calculated, who awarded the scores, whether they were discussed within the board as a whole, and whether the candidate was shown the completed matrix.
- Substantiations of the scores awarded to the candidate and the other board members.
- Answers to the following questions:
- 1. On which points does the board as a whole score best and worst, in your opinion, and why?
- 2. How do you plan to compensate for the weaker points?
- 3. What is the added value of the candidate with respect to the other board members?
- 4. Which competencies relevant to the position does the candidate possess, and how is this evidenced?
- 5. How much expertise and experience of climate-related and environmental risks does the candidate possess? How much of this do the other board members possess?
In your explanation of the scores, it is important that you specify why the candidate and board members were a particular score, e.g. based on relevant education and experience.
Example 1: If a proposed supervisory board member has worked in the banking sector for several years in various positions, you obviously assign them a high score on "knowledge of products and services". However, if you assign a high score to someone who has worked in a different sector, you must provide adequate motivation.
Example 2: if a candidate is proposed as a member of the investment advisory committee of a pension fund, and has worked at an asset management company for a number of years or has completed a high-level business accounting course, a higher score on "financial aspects" is only logical. If the candidate has gained their asset management experience in another way, you must be able to substantiate this.
You must take account of the statutory maximum number of supervisory positions a management or supervisory board member is allowed to hold. This means that you must demonstrate that the candidate meets the requirements of the Management and Supervision Act (Wet bestuur en toezicht – Wbt) or, in the case of pension funds or occupational pension funds, the composition of the candidate's FTE score, as required under the Pension Fund Governance Reinforcement Act (Wet versterking bestuur pensioenfondsen). To guarantee that the information you submit is complete, we recommend that you use our pension funds FTE score template. You can this webpage for the format. If the candidate is to be appointed at a significant institution subject to SSM supervision, the CRD IV requirements apply.
Please also provide an indication of the candidate's actual time commitment. You can do so by stating the average weekly or monthly time commitment for each of the secondary positions in the candidate's CV. You may also provide a separate document, such as the time commitment statement often used by pension funds.
Notes on preparations for the position
Based on the application file, we establish whether the candidate has the required expertise and experience, fits the job profile and adds value to the board as a whole. If this preliminary investigation presents us with a clear picture, we may issue a positive decision without having to interview the candidate.
A description of how the candidate has prepared for the position may help us form a comprehensive picture of their fitness. Examples of the candidate's activities include reading relevant documents, holding meetings or discussions with others within the organisation, attending meetings as an observer or participating in internal or external training programmes.
Referees must meet the following conditions:
- They must have a relevant professional background and must be sufficiently independent.
- They must be able to describe the expertise of the person to be assessed, experience and professional conduct.
- One of the referees must be the candidate's most recent superior or a fellow management or supervisory board member.
- At least one referee must work in the financial sector, but preferably at a different institution to the candidate's.
Please provide the referees' names, contact details, current position and relationship to the person to be assessed. In view of privacy regulations, please do not provide us with any further contact details than requested.
We will not necessarily contact all referees. Please inform your referees that we might not contact them.
Propriety Assessment Form
For a proposed appointment, the candidate must also complete the Propriety Assessment Form. If DNB or the AFM assessed the candidate's propriety less than three years ago and no changes to any relevant facts or circumstances have occurred since the previous assessment, there is no need to submit the form.
We advise candidates to always study the form in advance, as it explains what we mean by relevant facts, circumstances and antecedents, including examples.
Other relevant documents
You can add additional documents if you believe they provide us with a more comprehensive picture of the candidate or the position. Examples include a training or induction programme, assessment outcomes and management development assessments.
When signing an Initial Assessment Application Form in our Digital Supervision Portal, you must upload a signatory statement. This ensures that your application is signed by an authorised signatory of your institution. You will find the signatory statement in the Digital Supervision Portal.
Certificate of good conduct/criminal record check
As part of a propriety assessment, we check criminal records to determine whether the natural person has ever been involved in criminal acts that affect their propriety.
Since not all criminal offences are included in the Dutch judicial system, we will need a criminal records extract from some of the persons that are assessed for propriety in the context of a request for registration as a crypto service provider. A criminal records extract is a statement from a competent authority confirming that the person to be assessed has not committed any criminal offences that are relevant for the proposed position.
The following persons are required to submit a criminal records extract in the context of a propriety assessment:
- Persons having Dutch nationality who have resided outside the EU at any time during the past eight years.
- Persons having non-Dutch nationality who have resided outside the Netherlands at any time during the past eight years.
The infographic below shows the situations in which a criminal records extract must be submitted:
Please note that persons who have resided in multiple countries outside the Netherlands during the past eight years may have to submit multiple criminal records extracts.
A criminal records extract is available from the competent authority in the relevant country of residence and must meet the following conditions.
- The extract may not have been issued more than three months ago.
- If the extract is not in the Dutch or English language, you must also provide a translation in either Dutch or English, prepared and certified by a sworn translator.
Key function holder self-assessment (for pension funds and premium pension institutions)
Pension funds and premium pension institutions must substantiate the fitness of a board member who they propose to appoint to a key function in risk management or internal audit in the self-assessment form. This form can be downloaded at Forms & formats.
You will find more information (in Dutch only) on the fitness requirements for key function holders here.
- Clearing & Settlement Systems
- Clearing institutions
- Collective investment schemes
- Electronic money institutions
- Investment firms
- Payment institutions
- Pension funds
- Trust offices