2024-09-06
The Dutch Ministry of Finance, AFM, and DNB urge the European Commission to review the IFR and IFD to enhance risk-based regulation, ensure a level playing field, and increase governance proportionality. The regulators propose simplifying firm categorization, recalibrating capital requirements, and clarifying consolidated supervision to prevent regulatory arbitrage and address vulnerabilities. Additionally, they recommend making governance obligations explicit and establishing clearer thresholds for risk and remuneration committees to reduce administrative burdens.