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pc nid 94588 Aug 14, 2026 tojuri@vixio.com Netherlands De Nederlandsche Bank horizon scanning
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Netherlands' De Nederlandsche Bank Extends Non-Enforcement Period for Banking and Trading Book Separation

On August 13, 2026, De Nederlandsche Bank (DNB) announced it is extending the period during which it will not prioritise supervision and enforcement measures relating to the separation between the banking book and the trading book. This decision follows a recent call from the European Banking Authority (EBA) to temporarily deprioritise enforcement of these provisions. DNB will not prioritise supervision and enforcement measures concerning the relevant Fundamental Review of the Trading Book (FRTB) provisions on banking and trading book separation, and certain related reporting requirements, for credit institutions under its direct supervision until December 31, 2029. The EBA issued this guidance on August 3, 2026, following the European Commission's third delegated act of June 4, 2026, which introduced temporary operational adjustments to the revised market risk framework. The EBA determined that the current framework could create operational complexity and legal uncertainty for financial institutions. Consequently, it recommended that supervisors refrain from prioritising supervision or enforcement measures relating to the relevant FRTB provisions during this interim period. DNB endorses this position and will apply the recommendation to credit institutions under its direct supervision. However, DNB emphasises that financial institutions must continue preparing for full implementation of the revised market risk framework, including requirements concerning banking and trading book separation. This extension provides temporary relief while institutions work toward compliance with the comprehensive new requirements. The non-enforcement period represents a pragmatic approach to managing the transition, acknowledging operational challenges while maintaining expectations for eventual full compliance.

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Dutch Central Bank Extends Non-Enforcement Period for Banking and Trading Book Separation

On August 13, 2026, the Dutch Central Bank (DNB) announced it is extending the period during which it will not prioritise supervision and enforcement measures relating to the separation between the banking book and the trading book. This decision follows a recent call from the European Banking Authority (EBA) to temporarily deprioritise enforcement of these provisions. The DNB will not prioritise supervision and enforcement measures concerning the relevant Fundamental Review of the Trading Book (FRTB) provisions on banking and trading book separation, and certain related reporting requirements, for credit institutions under its direct supervision until December 31, 2029. The EBA issued a No-Action Letter on August 3, 2026, following the European Commission's third delegated act of June 4, 2026 , which introduced temporary operational adjustments to the revised market risk framework. The EBA determined that the current framework could create operational complexity and legal uncertainty for financial institutions. Consequently, it recommended that supervisors refrain from prioritising supervision or enforcement measures relating to the relevant FRTB provisions during this interim period. The DNB endorses this position and will apply the recommendation to credit institutions under its direct supervision. However, the DNB emphasises that financial institutions must continue to prepare for the full implementation of the revised market risk framework, including requirements regarding banking and trading book separation. This extension provides temporary relief while institutions work toward compliance with the comprehensive new requirements.