The IFR/IFD form the prudential framework for investment firms in the European Union (EU). Even though the IFR/IFD generally function well, the Dutch Ministry of Finance, the AFM, and DNB do consider it necessary to strengthen several elements of the prudential framework. In particular, the review of the IFR/IFD needs to improve the risk-based nature of the framework, ensure a level playing field for investment firms active inside and outside the EU, prevent regulatory arbitrage, and increase proportionality and clarity of governance requirements.
The recommendations are provided in the joint non-paper ‘Investment Firms Regulation and Directive (IFR and IFD) Review’ of the Dutch Ministry of Finance, the AFM, and DNB.