Your challenge

Embarking on the journey to offer financial services and tapping into new markets is exciting yet challenging. Before you can fully realize this ambition, it is essential to understand the qualifications for financial services and whether a license might be necessary. Navigating the license application landscape can be a pivotal moment in the lifetime of your business, and we understand that each organization’s journey is unique.

As you pursue a license, it’s important to be aware of the intricate landscape that lies ahead. This includes navigating the evolving regulatory framework, managing documentation requirements that evaluate your operations, risk management, governance structures, and engaging effectively with various stakeholders and regulators.

We recognize the importance of understanding the specific requirements and nuances associated with different types of licenses, including those for banking, insurance, payments, fund management, credit provision, intermediary and advisory services, crypto asset services, and crowdfunding. Our team is well-versed in identifying regulatory expectations and interpreting the communication with supervisory authorities. With our extensive experience and track record, coupled with market insights, we are well equipped to align your application with regulatory standards and best practices.

At Deloitte, we bring together a wealth of expertise to support you through this critical phase, whether you are navigating the complexities of a banking or insurance license application or pursuing more straightforward options such as a credit service provider license or crowdfunding license.

Our solution

We offer a strategic and comprehensive approach for navigating the complexities of the licensing application process, recognizing that this journey is a co-creation process with your team. By leveraging Deloitte’s multi-disciplinary network of professionals—including experts in strategy, tax, financial advisory, risk and controls, and accounting—we can source the right specialists tailored to your specific needs.

Our phased approach is designed to adapt to the unique requirements and maturity of your organisation. A license application project typically begins with a thorough preparation phase, during which we conduct a gap analysis and develop a comprehensive application package in collaboration with you. We then guide you through the formal submission process, closely liaising with the supervisory authorities to address any questions and interpret expectations. Our team is prepared to swiftly amend and provide additional documents as required in this process. Finally, upon successful application, we can assist with the transition to operational status, ensuring you are well-equipped to meet ongoing regulatory requirements and thrive in your business environment.

We recognize that each client has different starting points, available resources, and preferences. We can provide either full support or lighter touch assistance based on your specific needs. It is vital that we work shoulder-to-shoulder with you throughout this process, empowering your team with the knowledge and skills necessary to operate in line with applicable regulatory requirements once the license has been granted. Together, we will ensure that you are not just compliant, but also well-prepared to thrive in your operational environment.

Your challenge

In today’s ever-evolving regulatory landscape, financial institutions can utilize their mandatory requirements to boost their operational resilience by ensuring that their policy frameworks are consistently up to date and aligned with changing regulations. The swift pace of legislative shifts may present challenges, but it also opens the door for institutions to effectively implement new requirements within their daily operations. Institutions can create an effective and aligned policy framework that not only meets regulatory demands but also supports sustainable growth and success. This is a chance to refine processes and strengthen resilience in an ever-changing landscape.

Our solution

We partner with you to develop comprehensive policies in key areas such as remuneration, Anti-Money Laundering (AML), digital operational resilience (including outsourcing), sustainable finance, and more. Our expertise enables us to conduct thorough gap assessments between regulatory requirements and your existing policies, streamline policy drafting for new regulations, and simplify regulatory comparisons to identify significant changes in updated regulations. By leveraging our multidisciplinary expertise alongside advanced AI technologies, we efficiently and collaboratively build a robust policy framework tailored to your organisation's specific needs.

Our tailored approach ensures that the policies we create are not only compliant and practical but also aligned with your business objectives, ultimately enhancing your operational effectiveness while minimising costs. If desired, we are also happy to team up, and assist you with the seamless implementation of new or updated policies, ensuring smooth integration into your day-to-day business. It is our commitment to provide you with the insights and support necessary to navigate the complexities of the regulatory landscape for your business effectively.

Your challenge

Embarking on the path towards optimizing your organizational structure offers a great opportunity to enhance efficiency and reduce costs. By clarifying roles and responsibilities within your organization, you can unlock greater agility and streamline resource allocation, paving the way for enhanced decision-making and responsiveness. Moreover, supervisory authorities tend to favor clearly-organized groups with streamlined structures, which not only simplifies compliance but also enhances your standing in the marketplace. Let us partner with you to turn the challenges into exciting opportunities, to help you navigate these complexities effectively and set your organization up for a thriving future in a rapidly evolving business environment.

Our solution

As your trusted legal advisor and legal project manager in one, we possess extensive experience in advising, setting up, and implementing restructuring projects within the financial sector, including legal mergers or demergers, asset transfers and share transfers.

Our approach goes beyond simply advising on the legal aspects; we also support the practical implementation of the restructuring tailored to your organisation's needs. Our aim is to help you optimize resources, lower substantial costs—such as compliance, legal entity, and governance costs—achieve time efficiencies, and improve agility. We execute projects in a manner that fosters effective collaboration across the entire organisation, ensuring that every member understands what success looks like and is aligned towards achieving it.

During a restructuring project, it may be necessary to obtain a declaration of no objection (verklaring van geen bezwaar, DNO) from the supervisory authorities. We offer a comprehensive solution to assist you throughout the DNO application process, guiding you from A to Z.

Case study – internal banking mergers

We successfully assisted a major Dutch bank, part of a large conglomerate of financial institutions, in executing two legal mergers. This complex process involved the integration of two banking subsidiaries into the main bank, ensuring that all regulatory requirements were met throughout the journey. Our role was comprehensive, guiding the entire merger process from start to finish.

During the preparation phase, we translated the required actions into clear, practical business requirements, which were then assigned to specific stakeholders. This clarity facilitated a deep understanding among all stakeholders involved, enabling them to effectively fulfil their responsibilities. By acting as a central hub, we organized clear communication and collaboration between over 150 stakeholders, motivating them to complete their tasks in a timely manner. We guided the management and supervisory boards of the banks and the project SteerCo through the process, keeping them informed of the project's progress at every stage to ensure that nothing came as a surprise to them. This proactive engagement helped maintain alignment and support across all levels of the organisation.

In addition to internal coordination, we prepared requests for a declaration of no objection for both the Dutch Central Bank (De Nederlandsche Bank, DNB) and the European Central Bank (ECB). Our team played a pivotal role in guiding the regulators through the transformation process, maintaining regular communication to provide updates and address any concerns. After securing the necessary internal and external approvals, our concerted efforts culminated in the successful implementation of both legal mergers, solidifying the bank's position in the financial landscape. Moreover, the bank achieved significant cost and time efficiencies as a result of the mergers. This included reductions in supervisory costs, fewer reporting obligations, a streamlined organisational structure with fewer legal entities, and a decrease in the number of directors required. These outcomes not only enhanced operational efficiency but also positioned the bank for greater strategic agility moving forward.

Your challenge

A declaration of no objection (verklaring van geen bezwaar, “DNO”) is required when acquiring or increasing a qualifying holding in financial entities such as banks, investment firms, or insurance companies based in the Netherlands. Additionally, it is a mandatory requirement for significant transactions involving mergers, acquisitions of assets or liabilities, or corporate restructurings that meet certain thresholds specified in the Dutch regulations.

Navigating the application for a DNO can be a pivotal moment in your business, it could be the starting point of acquiring or expanding a qualifying holding, acquiring assets or liabilities, entering into a merger, or conducting a corporate restructuring.

In the process of obtaining a DNO, proper preparation is key – especially because supervisory authorities require comprehensive documentation to verify whether regulatory conditions are met. It is important to – together with all relevant stakeholders – assess the impact of the acquisition on both your business and the target, as well as to develop a strategic business plan that aligns with regulatory requirements. Securing approval from the supervisory authorities involves careful planning and execution. We are here to help you tackle these challenges and ensure a successful application process.

Our solution

We recognize that every DNO application is unique, and we are committed to tailoring our services to meet your specific needs with a comprehensive solution that assists you from A to Z in the process.

Our starting point would be a thorough analysis of your situation, advising you on the type of DNO you may need, and providing a DNO checklist to streamline your preparation for the application. We will help you develop a strategic project plan, oversee its execution, and coordinate effectively with various internal and external stakeholders. We collaborate closely with you to prepare the DNO application documents and supporting explanatory notes, detailing the rationale for the underlying transaction and its impact on your organisation and the target. Once your application is filed, we facilitate efficient communication with the supervisory authorities, addressing any questions that may arise during the submission and assessment phase.

We prioritize collaboration, empowering your organisation with knowledge transfer throughout the process. Our multidisciplinary expertise integrates legal, financial, strategic and operational insights to provide a holistic approach to your DNO application. With our deep understanding of regulatory standards and supervisory expectations, we anticipate potential challenges and deliver proactive solutions, helping you secure the necessary approvals from supervisory authorities efficiently and effectively. We take pride in our ability to anticipate potential challenges and provide proactive solutions, helping you secure the needed approvals from supervisory authorities efficiently and effectively.

Your challenge

Adequately qualified management board and supervisory board members are essential for the stability and integrity of our financial markets, as their expertise directly influences sound decision-making and effective risk management within the financial sector. In the current landscape of rapidly evolving financial regulations, the necessity of having a well-educated board to lead financial institutions has therefore never been more pronounced.

To fulfil their responsibilities effectively, board members are legally required to complete the fit and proper assessments conducted by the Dutch Central Bank (de Nederlandsche Bank, DNB) or the Netherlands Authority for the Financial Markets (de Autoriteit Financiële Markten, AFM), as well as to keep their knowledge up to par. To successfully navigate these assessments, board members must possess a comprehensive understanding of the financial regulatory framework pertinent to the financial institution they are leading, including regulations such as CRD/CRR, PSD/PSR, AIFMD, and the Dutch Financial Supervision Act (de Wet op het Financieel Toezicht, Wft) as well as relevant themes such as corporate governance, board room dynamics, sustainable finance and digital operational resilience.

Our solution

We partner with you to guide prospective board members through the fit and proper assessments, offering tailored training programmes that simplify complex regulatory topics. Our training ensures participants gain a clear and comprehensive understanding of the expectations set by supervisory authorities and other stakeholders. With extensive experience in training board members, we provide valuable benchmarks and clarifications regarding supervisory expectations, including insights into boardroom dynamics and potential interview questions related to these assessments. Depending on the needs of your prospective board members, these training sessions typically last for three to four hours or can be extended over multiple sessions if desired.

Having successfully trained numerous board members across the financial sector, we are well-positioned to enhance your board's effectiveness. Our specialised training programmes are designed specifically for current and prospective board members, delivered by trainers with a wealth of experience from both business and supervisory backgrounds. This ensures participants receive insights from experts who understand the nuances of these assessments. Upon completion, participants receive a certificate that validates their participation.

In addition to board training, we offer sessions for senior management, focusing on essential skills and in-depth knowledge of the regulatory environment relevant to their roles. Our bespoke sessions ensure your team is well-informed and equipped to make strategic decisions that meet regulatory requirements. Furthermore, we provide permanent education programs to keep your leadership team at the forefront of regulatory changes and best practices, and we are happy to tailor our offerings to meet your specific needs.

Your challenge

The Dutch remuneration landscape is distinguished by a strict regime that exceeds the minimum EU requirements, including measures such as the “bonus cap”. The framework encompasses specific provisions for compliance and enforcement, underscoring the importance of high standards in corporate governance and risk management. Additionally, it places a strong emphasis on integrating non-financial assessment criteria, such as ESG metrics, into remuneration policies. As this unique regulatory landscape continues to evolve, it is essential to establish a robust remuneration framework that aligns your business objectives with these elevated regulatory demands.

Remuneration within FSI is a hot topic for boards and senior management, attracting significant regulatory scrutiny. Strengthening your remuneration policy and procedures is essential to ensure compliance with the latest EU directives, regulations, key guidelines, and national laws, while also promoting transparency and accountability in remuneration practices. It is important to apply regulations proportionately to the size and complexity of your organisation, effectively adapting practices to address both regulatory oversight and competitive business needs. Our team is dedicated to helping you achieve these objectives.

Our solution

Deloitte is uniquely equipped to navigate the complexities of remuneration in the financial sector, offering an integrated multidisciplinary team comprising expertise in strategic rewards, governance, regulatory, and tax domains. Our extensive experience spans a wide array of subsectors, including local and global banks, asset managers, payment services providers, and FinTechs. Our specialists provide expertise across all areas of remuneration under one roof:

• Regulatory and employment law experts advise on interpreting regulatory requirements derived from EU and Dutch laws, standards, and guidelines, and are adept at engaging with supervisors.
• Executive rewards experts bring extensive experience in designing short and long-term incentives that ensure effective pay-for-performance alignment.
• Employment tax and legal experts assist in designing cost-effective, tax-efficient, and compliant compensation and payroll programs that align with talent strategies and the diverse needs of the workforce.

We offer comprehensive advisory services that address specific challenges related to remuneration governance, risk management, and policy implementation. By integrating our insights into your organisation with our extensive experience in this area, we can develop a tailored remuneration policy and assist in implementing practical day-to-day procedures suited to your needs. Furthermore, we provide ongoing support, including educational sessions for board members and reward teams, to ensure your organisation remains informed about regulatory developments and emerging trends. Our subject matter experts are attuned to the changes and developments pertinent to your organisation, ensuring compliance and positioning you ahead of the market.

Your challenge

The financial landscape is continuously being reshaped by a wave of new and updated legislation that presents a prime opportunity to innovate, strengthen client relationships and enhance operational resilience. Forthcoming reforms such as the Payment Services Directive 3 (PSD3) and its companion Payment Services Regulation (PSR) will elevate security, transparency and consumer protection, while the Capital Requirements Directive VI (CRD VI) and Capital Requirements Regulation (CRR) will impose tougher standards on risk management and capital adequacy. At the same time, from March 2026 onwards, crypto-asset service providers that facilitate transfers of electronic money tokens or operate custodial wallets will fall under both the Markets in Crypto-Assets Regulation (MiCAR) and PSD2, requiring a PSD2 license. To capture the full benefits of these reforms—and to safeguard seamless operations—you must act in time to recalibrate policies, systems and governance frameworks, ensuring robust compliance and sustainable growth in an increasingly demanding regulatory environment.

Our solution

We partner with you from the outset, standing up dedicated project teams and conducting a comprehensive gap assessment to diagnose how PSD3/PSR, CRD VI/CRR and any other new rules affect your policies, controls and systems. Drawing on our legal, compliance, financial and operational expertise, we co-create a tailored implementation roadmap, revise processes, adapt reporting infrastructures and embed robust governance arrangements to serve seamless alignment with the new requirements.

To secure lasting change, we deliver targeted training, leadership-development and change-management sessions that equip your teams with the knowledge and skills for ongoing compliance. We also manage every aspect of regulatory engagement — from license applications and notifications to follow-up dialogue — so you meet all deadlines with confidence. Once live, our continuous monitoring, horizon scanning and advisory support keep you agile in the face of further developments. Whether you require full end-to-end project leadership or focused assistance on select workstreams, our flexible approach transforms compliance into a source of resilience and competitive advantage.

By partnering with us, you will not only meet compliance requirements; but also empower your organisation with the knowledge and skills necessary to navigate ongoing regulatory expectations effectively. Together, we will ensure that your financial institution is positioned for success in its operational environment.

Your challenge

As a result of the EU Green Deal, there has been a significant increase in new European legislation focused on Environmental, Social, and Governance (ESG) matters, presenting a unique opportunity for financial companies to lead in sustainability efforts. Regulations such as the Sustainable Finance Disclosure Regulation (SFDR), the EU Taxonomy Regulation, the Corporate Sustainability Reporting Directive (CSRD), and the Corporate Sustainability Due Diligence Directive (CSDDD) provide a framework for organisations to define key performance indicators (KPIs) and monitor and report externally on specific ESG topics. This evolution in the regulatory landscape encourages financial institutions to adapt their operational business processes, not only to meet compliance requirements but also to contribute meaningfully to a more sustainable world.

Staying informed about ongoing developments in the ESG landscape is essential, as it allows organisations to embrace these changes proactively. By aligning their business strategies with sustainability initiatives, companies can position themselves as leaders in the transition towards a more sustainable economy. Furthermore, as authorities increasingly enforce ESG requirements, those who proactively engage with these regulations can mitigate risks and enhance their reputation, ultimately benefiting from the growing demand for responsible and sustainable business practices.

Our solution

We can collaborate with you to develop tailored solutions that address the challenges of the evolving ESG regulatory landscape. By identifying and managing risks associated with your sustainability aspirations, we enable you to concentrate on your core business operations. Our expertise in scoping helps you assess the applicability of relevant ESG legislation. We provide customised regulatory mapping to track upcoming legislation, regulatory developments, alignments, and initiatives, ensuring that you receive clear, pragmatic, and timely advice on the implications of current and anticipated sustainability legislation and policies at both national and European levels.

Moreover, we can assist you in seamlessly integrating sustainability into your current policies and practices, enhancing your operational resilience, and empowering your organisation to thrive in a dynamic regulatory environment. Our support includes helping you understand the obligations and actions necessary for operational readiness and providing you with a roadmap for implementation. With our expertise, we interpret specific legal provisions, technical standards, and Q&As arising from legislation relevant to your organisation and translate them to practical solutions.

Additionally, we can assess your current policies, procedures, and practices against upcoming legislation, helping you stay ahead of the market. We conduct comprehensive reviews and validations of third-party contracts—such as those with your clients and ESG data and tooling service providers—to ensure compliance. With extensive experience in policy drafting and reviewing, we can tailor your policies to meet regulatory requirements, including remuneration policies, risk management policies, investment policies, and due diligence policies, equipping you with the necessary frameworks to thrive in the sustainable finance landscape.