NETHERLANDS Trends and Developments Contributed by: Juliet de Graaf and Johannes de Jong, Osborne Clarke N.V.
ily refuse or hinder customers. The DNB plans to release the final proposal document in early 2024. The proposal follows the DNB’s call last year for a risk-based approach to preventing financial crime, as discussed in the report “ Van herstel naar balans ”. This approach emphasises effi - ciency and effectiveness in customer and trans - action checks, leveraging innovative technology like machine learning, and focuses on risk-based methods. These methods are intended to be more targeted and also prevent strict controls from unnecessarily obstructing customer access to banking services and the financial system. Following the publication of the report, finan - cial institutions and the DNB have discussed the implementation of this renewed approach in various roundtable meetings. The Dutch Bank - ing Association ( De Nederlandse Vereniging van Banken , DBA) has, based on these discussions, already published its own standards, offering examples of how banks can comply with spe - cific Dutch AML provisions. DORA In 2024, banks were required to prepare for DORA, which becomes fully applicable in Janu - ary 2025. DORA, an EU regulation aimed at enhancing the IT security of financial entities, focuses on several key areas: • ICT risk management: establishing principles and requirements for an ICT risk management framework; • third-party risk management: monitoring third-party risk providers and establishing key contractual provisions; • digital operational resilience testing: imple - menting both basic and advanced testing measures;
• ICT-related incidents: setting general require - ments for reporting major ICT-related inci - dents to competent authorities and sharing information on cyber threats; and • oversight of critical third-party providers: establishing an oversight framework for criti - cal ICT third-party providers. The timeline for implementing DORA includes a series of steps, such as public consultations and the delivery of policy products. The DNB has already started monitoring banks’ compliance with DORA’s provisions and pub - lished a significant amount of guidance on the topic. Given DORA’s complexity and profound impact on both banks’ internal operations and their outsourcing chains, compliance with DORA was a top priority for every Dutch bank manager in 2024. The process of becoming DORA com - pliant has proven burdensome, which for some banks may result in gaps in DORA compliance by January 2025. The DNB has expressed its opinion that all banks must be fully compliant by the 2025 application date and we expect enforcement measures from the DNB in case of non-compliance. Payment Developments In 2024, payment preferences in the Netherlands are rapidly changing due to the emergence of new technologies such as social commerce, dig - ital wallets, and self-scan checkouts. Research indicates that 61% of Dutch consumers use self-scan checkouts. Additionally, paying after delivery (used by 35% of Dutch consumers) is a popular payment method. iDeal, the prominent online payment scheme in the Netherlands, is expected to continue to lead in 2025 (in 2024 approximately 70% of all online purchases were made using iDeal).
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