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On June 17, 2026, the Dutch Authority for the Financial Markets (AFM) published its Supervisory Review and Evaluation Process (SREP) Market Overview 2025, identifying significant gaps between policy frameworks and operational execution across the financial services sector. The AFM found that while many financial institutions have established robust policies and procedures covering compliance, regulatory adherence, and professional competence, the practical implementation of these frameworks remains insufficient. Internal controls are frequently not executed consistently or properly documented, and processes are not regularly evaluated. This creates a risk that policies exist in theory but fail to function effectively in practice. The AFM emphasises that daily application of policies is critical to their effectiveness. Information and communications technology (ICT) risk management presents a particular concern. As the sector becomes increasingly dependent on information technology systems, management of these risks lags behind. Key components including vulnerability identification, backup testing, and incident preparedness are inadequately implemented across many institutions. While organisations typically identify problems effectively, they allocate insufficient resources to prevention. The AFM notes this vulnerability is particularly concerning given rising cyber threats and emphasises the need for stronger governance and clear agreements with external IT service providers. The AFM also identified unclear allocation of roles and responsibilities across several areas, including best execution, sustainability, and third-party collaboration. Without explicit assignment of accountability and robust process controls, critical tasks risk being overlooked and customer interests may be compromised. The AFM expects market participants to use the SREP Market Overview to conduct critical self-assessments and implement necessary improvements. The full SREP Market Overview 2025 is available on the AFM website.