Dutch Banks Adopt Harmonized EU Framework Under CRD VI

The Dutch government has implemented the sixth Capital Requirements Directive (CRD VI) into national law through the Capital Requirements Implementation Act 2026, which took effect on September 22, 2026. This implementation follows closely behind the direct application of the Capital Requirements Regulation III in the Netherlands since January 1, 2025.

The new framework replaces the country's previous second-tier assessment regime for banks with a harmonized EU framework for key function holders. Under CRD VI, banks and approved financial and mixed financial holding companies are now responsible for assessing the suitability and propriety of these individuals.

However, external assessments by the Dutch Central Bank (De Nederlandsche Bank, DNB) or the European Central Bank (ECB) will still be required for the heads of internal control functions and chief financial officers at large institutions. Banks must ensure they have proper internal assessment processes in place, keep relevant information up-to-date and documented, and submit complete assessment applications on time when external assessments are needed.