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Dutch Corporate Governance Code 2025

First Glimpse

A Deloitte publication introducing how Dutch listed companies are responding to the Dutch Corporate Governance Code 2025, with a focus on the Statement on Risk Management (Verklaring omtrent Risicobeheersing - VOR).

Access the full publication — explore it online or download it for later. Get straight to the insights that matter for your organisation.

What's inside

Our First Glimpse: Dutch Corporate Governance Code 2025 (the "Code 2025") is based on an initial review of all 96 financial year 2025 annual reports filed on the AFM Register for Financial Reporting through March 2026 (the register covering companies whose securities are admitted to trading on a regulated market in the Netherlands).

This publication provides a sharp snapshot of how companies are interpreting and applying the Code 2025, with focused scrutiny of the best-practice provisions on the VOR.

Drawing on the reviewed reports, the analysis highlights early disclosure patterns, common interpretations and notable divergences. Taken together, the findings offer a practical glimpse into how companies have interpreted and responded to the VOR's best-practice provisions.

96

annual reports analysed from the AFM Register for Financial Reporting

78

companies applied the Dutch Corporate Governance Code 2025

81%

non-financial companies vs 19% financial companies

Reflect on these questions with your organisation in mind:

  • How is your organisation currently applying the Dutch Corporate Governance Code 2025 in light of the insights from this publication?
  • Where are there gaps between current market practice and your organisation's disclosure approach, and where do you aspire to be?
  • How can you strengthen your risk management and control systems and the management level of assurance/certainty?

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Read the publication to discover the insights for your organisation and request a walkthrough to focus on your organisation's corporate governance and reporting priorities.

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