NETHERLANDS Trends and Developments Contributed by: Juliet de Graaf and Johannes de Jong, Osborne Clarke N.V.
Osborne Clarke N.V. Jachthavenweg 130 1081 KJ, Amsterdam The Netherlands Tel: +31 20 702 8600
Email: charlotte.schuurman@osborneclarke.com Web: www.osborneclarke.com/nl/locations/the- netherlands
Introduction The regulatory supervision by the Dutch Central Bank ( De Nederlandsche Bank , DNB) is shaped by its four-year outlook on regulatory supervi - sion 2021-2024 ( Visie op toezicht 2021-2024 ). This outlook focuses on risk-based supervision, responding to technological innovations, ESG considerations, and combating money launder - ing and fraud. Looking ahead, Dutch-licensed banks face new challenges and regulatory changes. The Digi - tal Operational Resilience Act (DORA) aims to bolster the digital operational resilience of the financial sector and requires banks to implement effective digital risk management practices. The DNB has already started monitoring banks’ compliance with DORA’s provisions, focusing on their capacity to manage ICT-related disruptions. Additionally, the Markets in Crypto-Assets Regu - lation (MiCAR), another key piece of legislation coming in next year, is set to impact the sector. However, unlike banks in some other jurisdic - tions, Dutch-licensed banks have shown limited interest in offering crypto-asset services. The full impact of MiCAR on Dutch-licensed banks is
yet to be seen and will be evident in 2025 when MiCAR becomes applicable. The banking sector also anticipates major regu - latory updates with the implementation of the Capital Requirements Regulation 3 (CRR3) and the Capital Requirements Directive 6 (CRD VI), which entered into force on 9 July 2024 and will be applicable in 2025-2026. These updates will introduce significant changes to the regulatory framework, impacting various aspects of bank - ing operations and risk management. Economic Developments In 2024, global uncertainties such as tensions in Gaza, continued to influence the Dutch econo - my. Despite these challenges, the Netherlands showed resilience, reflected in the inflation rate for 2024 which is projected at 2.5%. This is a further decrease compared to the rates for 2023 (4.12%) and 2022 (11.6%). The expected infla - tion for 2025 is set at 2.0%. Lower inflation coupled with a recovering econo - my positively impacted financial stability in 2024, which is expected to continue in 2025. Although the Dutch economy did not experience signifi - cant growth in 2023, a severe recession was
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