Dutch AFM Ends Three-Year Reliability Reassessments in Caribbean Netherlands, Keeps Reporting Duty

Key Takeaways

• Effective July 23, 2026, the AFM has discontinued the mandatory three-yearly reliability reassessment of (co-)policymakers at financial undertakings in Bonaire, St.
• Eustatius, and Saba.
• The obligation to report relevant changes or new facts affecting reliability without delay remains fully in force.
• Compliance teams should shift from calendar-driven reassessment preparation to event-driven monitoring and escalation.

Deep Dive

Effective July 23, 2026, the AFM has discontinued the mandatory three-yearly reliability reassessment of (co-)policymakers at financial undertakings in Bonaire, St. Eustatius, and Saba. The obligation to report relevant changes or new facts affecting reliability without delay remains fully in force. Compliance teams should shift from calendar-driven reassessment preparation to event-driven monitoring and escalation.

The change aligns Caribbean Netherlands supervision with the European Netherlands model of "once reliable, always reliable, unless facts or circumstances warrant a new assessment." It follows from the Financial Markets Amendment Decree 2026 and is intended to reduce administrative burden for enterprises and persons subject to assessment. Institutions no longer need to prepare for or submit periodic reassessment filings for (co-)policymakers who previously received a positive evaluation.

The reliability requirement itself is unchanged. It remains an ongoing statutory requirement, and the AFM stresses that abolishing the periodic review does not make it less important. Financial institutions and the (co-)policymakers themselves must report relevant changes or new facts that may affect reliability to the AFM without delay. If such facts arise, the AFM may open a new reliability assessment. Because the reporting duty applies to both the institution and the individual, a gap in internal escalation could create exposure for both parties.

The key date is July 23, 2026, when the periodic reassessment ended. The release does not specify transitional arrangements for reassessments already scheduled or in progress, so institutions should confirm their status with the AFM. The AFM has published guidance on which changes must be reported, when, and how, and has provided info@afm.nl for questions. Note that "without delay" is not defined by a fixed deadline in this release.

Recommended actions: (1) remove the three-year reassessment cycle from compliance calendars and update fit-and-proper procedures; (2) review the AFM guidance on reportable changes and map those triggers to internal events, such as criminal or regulatory proceedings, financial difficulties, conflicts of interest, and other integrity concerns; (3) establish clear escalation and reporting procedures, with defined ownership and timelines for notifying the AFM; (4) remind (co-)policymakers of their personal reporting duty and consider periodic attestations or screening as an internal control; and (5) document the rationale for the changes and retain evidence of ongoing monitoring.

Risk implications: the administrative burden falls, but the risk of undetected or late-reported reliability issues rises, since the periodic review no longer acts as a backstop. Institutions that depend on the AFM cycle to surface issues will need stronger internal monitoring. Failure to report promptly could lead to supervisory action, including a new assessment, and could cause reputational and governance consequences. Overall impact is low to moderate, with the most significant changes in process design and governance accountability.

Source: Dutch Authority for the Financial Markets