AFM Decision on Deferred Publication of the Volume of Certain Transactions in Dutch Government Bonds

1 Decision of 14 April 2026 on the deferred publication of the volume of executed transactions relating to government debt instruments in connection with Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014. The Authority for the Financial Markets, having regard to, Article 11(3) of Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012 (MiFIR); and Article 2(1) in conjunction with Annex 10 of the EU Regulations Wft Decision; decides: Article 1 Scope This Decision applies to transactions in government debt instruments issued by the State of the Netherlands that are classified in Group 1, as defined in Table 2.2 of Annex III to Delegated Regulation (EU) 2017/583, Category 1, as defined in Table 2.6 of Annex III to Delegated Regulation (EU) 2017/583. Article 2 Deferred publication Market operators and investment firms operating a trading venue shall publish the volume of individual transactions in the government debt instruments referred to in Article 1 no later than the end of the trading day. Article 3 Entry into force This Decision shall enter into force on 4 May 2026. Adopted in Amsterdam on 14 April 2026.

2 Explanatory Memorandum

1. Pursuant to Article 10(1) of MiFIR, market operators and investment firms operating a trading venue shall publish the price, volume, and time of executed transactions for bonds traded on the relevant trading venue. The details of these transactions shall be published within a timeframe that approximates real-time as closely as technically feasible.
2. To avoid exposing liquidity providers to unnecessary risk in such transactions, it is possible to defer the publication of certain transaction details. In accordance with Article 11 of MiFIR, market operators and investment firms operating a trading venue may defer the publication of the details of executed transactions relating to bonds traded on a trading venue, including the price and volume.
3. Competent authorities of a Member State may, with regard to government debt instruments issued by that Member State or classes thereof, under Article 11(3) of MiFIR, permit the following: a) the omission of the publication of the volume of an individual transaction for an extended period of up to six months; or b) the publication of the details of several transactions in aggregated form for an extended period of up to six months.
4. The AFM is designated as the competent authority responsible for the implementation and enforcement of MiFIR under Article 2(1) of the EU Regulations Wft Decision in conjunction with Annex 10 thereto.
5. By this Decision, the AFM has determined to permit the omission of the publication of the volume of an individual transaction with a size between €15 million and €50 million, relating to government debt instruments issued by the State of the Netherlands with an outstanding issuance amount of €5 billion or more, until no later than the end of the trading day. Upon expiry of the deferral period, all details of the individual transactions shall be published. The extension applies across the entire Union to transactions in these instruments.1
6. This Decision contributes to a harmonised transparency regime and a harmonised deferral scheme regarding transactions in government debt instruments at the European level. National competent authorities permit publication no later than the end of the trading day with regard to sovereign bonds issued by their Member State.2 For government debt instruments not issued by a Member State, a Decision of the same nature has been adopted by the European Securities and Markets Authority (ESMA).3
7. Investment firms that execute transactions, for their own account or on behalf of clients, relating to the sovereign bonds referred to in Article 1 of this Decision that are traded on a trading venue shall also publish the volume of those transactions no later than the end of the trading day.4
8. For completeness, it is emphasised that this Decision is limited to what is specified in point 5. Publication of the details of several transactions in aggregated form 1 Recital 10 of Regulation (EU) 2024/791. 2 ESMA List of supplementary deferrals for sovereign bonds under MiFIR, 17 February 2026, ESMA74-276584410-11142. 3 ESMA Decision of the Board of Supervisors, 19 February 2026, ESMA74-276584410-11245. 4 Article 21(1) and (4) of MiFIR.

3 Definitions 9. The terminology and definitions in this Decision have the same meaning as in the Financial Supervision Act, Directive 2014/65/EU, and MiFIR. Consultation 10. The AFM did not consult on this Decision, as a public consultation or consultation of relevant market participants is not required under Article 11 of MiFIR. Furthermore, it constitutes a relaxation of the standard to which all national competent authorities have agreed, meaning the AFM does not consider consultation necessary. Publication 11. The AFM publishes a notice of this Decision at the following location: https://www.afm.nl/ 12. ESMA publishes on its website a list of each deferral permitted in accordance with Article 11(3) of MiFIR. This list can be found at the following location: ESMA publishes a list of supplementary deferrals for sovereign bonds. 13. The Decision shall enter into force upon publication in the Staatscourant, with effect from 4 May 2026.