On 22 September 2026, the Capital Requirements Implementation Act 2026 (Implementatiewet Kapitaalvereisten 2026) entered into force, implementing the sixth Capital Requirements Directive (Directive (EU) 2024/1619, CRD VI) into Dutch law. The Implementation Act follows the Capital Requirements Regulation III (Regulation (EU) 2024/1623, CRR III), which is applicable in the Netherlands directly since 1 January 2025. The authorisation regime for branches of third country banks providing core banking services in the European Union (EU) will enter into force on 11 January 2027.
As a result of the implementation of CRD VI, the national second-tier assessment regime for banks has been replaced by a harmonised EU framework for key function holders. Banks and approved financial and mixed financial holding companies are now primarily responsible for assessing the suitability and propriety of these individuals. External assessment by the Dutch Central Bank (De Nederlandsche Bank, DNB) or the European Central Bank (ECB) is required only for the heads of internal control functions and chief financial officers at large institutions. Banks must therefore ensure that they have appropriate internal assessment processes in place, keep the relevant information up to date and properly documented, and submit a complete assessment application in good time where an external assessment is required.
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