The AFM report Trend Outlook 2026 shows how geopolitics, technology and sustainability are becoming increasingly interconnected. For financial institutions, these are not abstract developments. They directly affect the licence to operate, supervisory expectations and the strategic choices that must be made now.
The core message: the financial system is becoming more complex, less predictable, and increasingly dependent on digital and geopolitical stability. As a result, adaptability is becoming more important than mere compliance with rules.
Fragmentation of the financial system
Geopolitical tensions and protectionism are leading to reduced free capital flows and increased regional bloc formation. This increases both financial and operational risks. Institutions must have scenarios ready for shocks to markets, valuations or international payment channels.
Digitalisation and AI
AI is fundamentally transforming advice, trading and risk management. While this brings efficiency gains, it also introduces new risks, such as bias, limited explainability and growing cyber threats. AI-driven fraud is becoming scalable. The AFM will explicitly assess explainability, governance and data quality.
Sustainability under pressure
Climate risks are increasing, while support for ESG is declining in some countries. This heightens uncertainty and the risk of greenwashing, while at the same time making the structural integration of climate risks even more relevant. This increases the importance of designing ESG processes that remain robust amid changing regulations, rather than having to be adjusted year after year.
Internationalisation with friction
European integration continues, while global rules are diverging. As a result, compliance is becoming more complex and increasingly cross-border in nature.
Digitalisation of financial crime
Deepfakes, synthetic identities and crime-as-a-service undermine trust in digital financial services and require new forms of supervision and detection. Institutions must demonstrably have accelerated detection mechanisms in place; traditional KYC and AML processes are no longer sufficient.
These trends have a direct impact on governance, compliance and risk management.
Digital resilience is no longer an IT issue, but a strategic prerequisite. DORA makes this explicitly assessable.
AI requires clear governance, ethical frameworks and transparency. Institutions must be able to explain how AI outcomes are generated.
At the same time, institutions must be prepared for geopolitical shocks, cyber incidents and climate impacts.
The role of governance and compliance is therefore shifting:
• from reactive to strategic;
• from rule-following to demonstrable resilience;
• from ex post control to embedding resilience, transparency and continuity.
Supervisors are working more closely together at European level, while responsibility for digital resilience remains national. The AFM is placing greater emphasis on the substantiation of choices, governance, data quality and internal controls. Institutions must actively protect their licence to operate by structurally embedding ESG, responsible use of AI and cybersecurity. At the same time, complexity is increasing due to geopolitical tensions and further European integration.
Five strategic steps for 2026
The question is not whether these developments will have an impact, but how well prepared your organisation is. Trend Outlook 2026 shows that the supervisory landscape is shifting from “complying with rules” to demonstrating organisational resilience. The AFM is placing particular emphasis on governance, explainability and robustness. Institutions that anticipate these developments now will not only strengthen their resilience, but also reinforce trust among clients, supervisors and the market.
The shift described in Trend Outlook 2026 requires not only vision, but also execution. Embedding digital resilience, AI governance, ESG and geopolitical scenarios in practice affects legal frameworks, risk management and compliance simultaneously. The real challenge lies in this interconnection.
Projective Group supports financial institutions in translating supervisory signals and strategic ambitions into concrete design, governance and control measures across Legal, Risk & Compliance. From establishing robust governance structures and AI and data policies to strengthening operational resilience, implementing DORA and future-proofing compliance and risk functions.
In this way, we help organisations not only to meet evolving expectations, but to become demonstrably resilient in a complex and uncertain environment.
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