The update concerns mortgage advice standards for consumer mortgage products provided by advisers, which falls within the retail lending domain as mortgages are consumer credit products regulated under lending frameworks.
Secondary tag reflects the investment/advisory dimension of mortgage suitability advice, though this is primarily a conduct rule for lending advisers rather than a pure investment services update — requires human review for appropriateness.
Specialism
The update establishes enhanced standards for mortgage advisers to provide suitable, tailored advice to consumers based on individual circumstances, which is a core Conduct of Business obligation.
Mandatory inheritance: Conduct of Business is a child of Governance, so Governance must be raised as the secondary tag.
2026-04-10 08:25:55·tojuri@vixio.com
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Vernieuwde handvatten voor hypotheekadviseurs voor passend advies
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TITLE: Netherlands' Financial Conduct Authority Updates Mortgage Adviser Guidance on Suitable Advice
BODY:
On 9 April 2026, the Netherlands' Authority for Financial Markets (AFM) published an updated Mortgage Advice Guideline (Leidraad Hypotheekadvisering) to enhance standards for providing suitable mortgage advice to consumers.
The updated guidance emphasises the independent professional role of mortgage advisers as a core principle. Advisers are expected to critically evaluate client wishes rather than simply following them, providing substantiated advice tailored to each client's personal circumstances in accordance with Article 4:23 of the Financial Supervision Act (Wft). The guideline covers the entire advice process from initial consultation through aftercare, with enhanced emphasis on questioning inconsistencies in client information and explicitly stating assumptions when data is incomplete. The guidance adopts a proportionality approach, allowing advisers to tailor the depth of their work to each unique client situation rather than applying a standardised checklist.
Two new topics have been added at market request: sustainability and relationship termination. For sustainability, the guidance describes how advisers should help clients identify sustainability options, financing possibilities, and potential financial consequences. For relationship termination, it emphasises the importance of advisers clearly discussing possible risks so clients understand personal implications.
The AFM received 23 responses during the consultation period on a draft version of the guidance. The feedback statement outlines how these responses were incorporated into the final text. The AFM will continue monitoring market compliance and whether consumers receive suitable advice in practice.
The updated guideline and feedback statement are available on the AFM website.