meta_id 2972605

On March 16, 2026, the Netherlands Authority for the Financial Markets (AFM) published improvement points for investor protection compliance among smaller asset managers, based on risk-focused examinations conducted during 2024 and 2025. The AFM identified compliance risks across seven key regulatory standards for investor protection. The improvement points address: suitability assessments and documentation; product approval and review processes (PARP); professional competence of staff; cost transparency; conflict of interest management; incident reporting to the AFM; and compliance function design. For suitability assessments, the AFM expects asset managers to actively gather information about clients' financial situations, investment objectives and preferences, with clear documentation of how this information influences investment decisions. Regarding PARP, asset managers must develop and test financial instruments carefully to ensure they align with target client needs and do not cause unintended harm. Staff providing investment information or advice must demonstrate professional competence through Digital Services Institute (DSI) registration or equivalent alternatives. Cost transparency requires asset managers to disclose all costs and charges both before and after investment, adjusted to individual client circumstances, with timely notification of any changes. Conflict of interest policies must identify and mitigate incentives such as volume and margin advantages, particularly when asset managers distribute their own financial instruments. Asset managers must establish clear procedures for timely reporting of integrity and information security incidents to the AFM. Finally, compliance functions must include structural monitoring, clear responsibilities, and sufficient expertise, with asset managers remaining accountable for compliance quality even when outsourcing. The AFM expects market participants to actively implement these improvement points and make necessary adjustments. The AFM's publication "Voldoen aan normen beleggersbescherming: wat betekent dit voor u?" provides detailed guidance supporting implementation.