Projective Group’s Risk & Compliance specialists closely monitor financial law and regulation developments. Using our compliance software, Ruler, we keep track of all current affairs. We then determine the impact of the changes and translate the developments into our clients’ daily practice.
What developments should your organisation be aware of? In our quarterly Regulatory Updates, we provide a structured overview of regulatory changes and their impact on financial institutions. In this article, we highlight a number of developments.
Which developments should you be taking into account?
In our quarterly Regulatory Update, we provide a structured overview of changes in legislation and regulation and their consequences for financial institutions. In this article, we highlight a number of topics from the Regulatory Update for Q1 2026.
Retrospective
Which legislation and regulation have recently entered into force?
Instant payments Since 9 October 2025, banks have been required to execute instant payments. In addition, both banks and other payment service providers must offer a service enabling verification of whether the beneficiary’s name matches the entered IBAN number, for both standard and instant payments.
Amended reporting under IFR/IFD Since 20 November 2025, an amended implementing regulation applies to reporting under the Investment Firm Regulation (IFR) and Investment Firm Directive (IFD). As a result, investment firms in categories 1 and 2 may report using the same COREP templates as banks. No changes apply to category 3 firms.
SREP guidelines for managers On 16 December 2025, the Dutch Central Bank (DNB) published the final SREP guidelines for managers. As a consequence, the former ICAAP policy rule for investment firms and investment institutions under the Financial Supervision Act 2015 (Wft 2015) has been repealed.
Implementation Act on the Prevention of Money Laundering and Terrorist Financing
On 4 July 2025, the Dutch Ministry of Finance launched a consultation on the implementation of the Sixth Anti-Money Laundering Directive (AMLD6) and the Anti-Money Laundering Regulation (AMLR) into Dutch law. The legislative proposal implements AMLD6 and proposes repealing the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), replacing it with a new Implementation Act.
The proposal also introduces numerous amendments to the Trust Offices Supervision Act 2018 (Wtt 2018), including the repeal of a significant number of provisions. Under the AMLR, trust offices will be required to take less extensive measures when establishing the Ultimate Beneficial Owner (UBO).
The proposal indicates that the Netherlands is opting for a minimum implementation approach, aiming to limit additional regulatory burdens as much as possible.
This means that the Netherlands has chosen to:
Lower the national cash payment limit to €3,000 (instead of the EU threshold of €10,000);
Introduce a cost-covering fee for access to the UBO register for both obliged entities and parties with a legitimate interest, while retaining the possibility to refuse access where there are security risks for the UBO;
Extend the bank account information portal to include additional administrative characteristics of products and clients;
Allow the Financial Intelligence Unit (FIU) to restrict access to police data where disclosure could jeopardise an ongoing investigation.
The Netherlands has decided not to make use of the following Member State options:
Extending the scope to additional sectors beyond the list of obliged entities under the AMLR;
Broadening the definition of Politically Exposed Persons (PEPs) to include siblings of PEPs or undertakings of local authorities;
Transferring supervisory responsibilities to self-regulatory bodies (such as professional organisations for lawyers or civil-law notaries), meaning supervision will remain exclusively with public supervisory authorities.
Bill Implementing the Pay Transparency Directive
The European Pay Transparency Directive entered into force on 7 June 2023. The implementation deadline for Member States is 7 June 2026. The Netherlands has already indicated that this deadline will not be met and is aiming for implementation as of 1 January 2027.
The objective of the bill is to promote equal pay between men and women. Women still frequently earn less than men for equal or equivalent work. The proposal introduces various measures to increase transparency around remuneration in order to reduce the gender pay gap.
Employers must be transparent about their pay structures, which must be based on objective and gender-neutral criteria (such as skills, responsibilities and working conditions). This already applies at the recruitment stage: the starting salary or pay scale must be disclosed in advance, and asking candidates about their previous salary will be prohibited.
Employees will have the right to information about their own salary and the average salary of colleagues performing comparable work. Where an employer is unable to justify a pay difference on objective and gender-neutral grounds, the employer must rectify the discrepancy within a reasonable period. This applies to any unjustified pay difference.
For larger organisations, reporting obligations will apply:
≥ 250 employees: annual reporting from 7 June 2027
150–249 employees: reporting every three years from 7 June 2027
100–149 employees: reporting every three years from 7 June 2031
Unexplained pay gaps exceeding 5% must be resolved within six months. Failing this, a mandatory joint pay assessment with the works council or trade union will be required, including the development of an action plan.
The transparency requirements apply to both basic pay and supplementary or variable remuneration.
Revised Consumer Credit Directive (CCD2)
The revised Consumer Credit Directive (CCD2) forms part of the European Commission’s broader consumer policy framework.
Key changes include:
The rules will also apply to small loans below €200;
Advertisements will be subject to fewer mandatory information requirements, improving clarity and readability;
Stricter rules will apply regarding the information consumers must receive prior to entering into a credit agreement, and the timing of such information;
Misleading sales practices will be prohibited, such as pre-ticked boxes, tied selling and unsolicited offers.
The Netherlands must still transpose this revised Directive into national law. The new rules will apply from 20 November 2026.
An important change is that deferred payment arrangements will now be considered a form of credit. As a result, Buy Now, Pay Later services and deferred debit cards will fall fully within the scope of the legislation.
In addition, the rules governing creditworthiness assessments will become stricter, including:
Mandatory consultation of the Dutch Credit Registration Office (BKR);
Stricter requirements for information provision and advertising;
Restrictions on the use of personal data;
Additional protection for minors.
The Dutch Authority for the Financial Markets (AFM) will also be granted the power to restrict or prohibit high-risk credit products.
Looking Ahead
Which upcoming legislative and regulatory developments should you prepare for?
In our next Regulatory Update, we will provide further insight into developments including:
The Digital Omnibus proposal, including amendments relating to:
We hope this article has provided you with a clear overview of recent developments. As legislation and regulation continue to evolve, it is essential to ensure that nothing is overlooked. We therefore invite you to request a tailored Regulatory Update (available in both Dutch and English).
Our quarterly report provides:
A clear overview of current developments;
Insight into forthcoming legislative changes and consultations;
An assessment tailored to your organisation and activities.
Our experienced consultants will explain the key points, answer your questions regarding the interpretation of legislation and support you in determining next steps and practical implementation. If required, we will work with you to develop a concrete action plan for updating policies and procedures.
This ensures that you remain prepared for new regulatory developments and retain control over their impact on your organisation.
Please feel free to contact us without obligation for further information.
