Combating Discrimination by Banks: From Insight to Action

ANALYSIS REPORT Combating Discrimination by Banks: From Insight to Action In brief: Combating discrimination in financial services aligns with the AFM’s mission: working towards fair and transparent markets and contributing to sustainable financial well-being. This includes companies that actively work against discrimination in their services. Our research into how several major banks combat discrimination provides the entire sector with practical tools for (further) strengthening their anti-discrimination approach. MAY | 2026

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 2 Table of Contents Introduction 4 Background and Objective 4 Key Findings 5 Design and Scope 5 Findings per Expectation 7 Expectation 1. The board ensures a shared vision on combating discrimination 7 Expectation 2. The company is set up to detect and effectively address discrimination 7 Expectation 3. The organizational culture is aimed at combating discrimination 8 Expectation 4. The company ensures appropriate communication during customer investigations 8 Expectation 5. The company collects signals and complaints to prevent discrimination 9 Appendix: Research methodology with description of maturity levels 10

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 3 Preface The Dutch Financial Markets Authority (AFM) views combating discrimination as a significant societal task and feels responsible for contributing to it. As an independent conduct supervisor, we contribute to sustainable financial well-being in the Netherlands. The AFM advocates for appropriate financial products and services, and careful customer treatment. The AFM is not the supervisor for the non-discrimination principle, but believes that combating discrimination aligns with its mission. Financial companies can use these recommendations to strengthen their approach against discrimination.

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 4 Introduction Background and Objective People (particularly those with a non-Western migration background) experience discrimination, also in their contact with banks. This experience is largely (but not exclusively) related to customer and transaction investigations that banks conduct to prevent abuse of the financial system. Countering money laundering risks can lead to specific customer groups being denied access to products and services that others do have access to. Additionally, they may face excessive scrutiny and discrimination in service provision. Discrimination is prohibited by law, and the societal interest in combating it is substantial. The Dutch Financial Markets Authority (AFM) supervises, based on the Financial Supervision Act (Wft), the safeguarding of customer interests by financial companies when delivering financial products and services. Furthermore, the AFM oversees orderly and honest business operations, including customer acceptance and selection policies. Customer interests are under pressure when companies must weigh different interests. In conduct supervision, we generally observe that commercial pressure can lead to violations of customer interests. In cases of discrimination, countering risks can also lead to violations of customer interests. The AFM and De Nederlandsche Bank (DNB) have jointly initiated projects aimed at combating discrimination. 1 2 Where processes aimed at countering money laundering and terrorist financing touch upon customer interests, an overlap arises between the supervision of the AFM and DNB. The AFM and DNB therefore conducted research to give banks insight into their progress in combating discrimination, and to further encourage their professionalization. The DNB research started in March 2025, and the results were published in September 2025. The AFM has conducted research since September 2025 at five banks on how they combat customer discrimination, with the results presented in this report. The objective of this report is to encourage banks to strengthen their approach to discrimination. The expectations in this report apply to all banks (and other financial companies with similar processes). This report provides guidance for improvements that have been applied by research participants. Based on the research findings, we have compiled an overview of the key recommendations. We encourage all banks to use the recommendations in this report to actively combat discrimination. The AFM will continue to advocate for an inclusive financial sector in the future. The AFM is positive about the improvements initiated by the research participants. Sustained improvement requires relentless attention to combating discrimination. Furthermore, the AFM will conduct research in the future on financial companies that have not yet participated. 1 DNB Report (2024): Combating discrimination by banks in compliance with the Wwft 2 DNB Report (2025): Actively combating discrimination - Managing the risk of discrimination in compliance with the Wwft and the Sw

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 5 Key Findings The AFM observes that research participants share constructively and openly what they are doing to combat discrimination. All research participants now acknowledge the problem of experienced discrimination in their service provision. In discussions, most participants describe that acknowledging discrimination took time. With the gained insights, they have proactively started implementing improvements. Most companies now adopt a broader perspective on discrimination than a few years ago. Discussions reveal that most participants use a scope broader than the gatekeeper function. Although investigations to detect discrimination in processes and programs to increase awareness often started in departments responsible for countering financial crime, they are now often rolled out more broadly within the company. Furthermore, participants acknowledge that discrimination can be an unintended consequence of interpretations and working methods, and that discrimination can also occur indirectly if a process makes distinctions based on other characteristics. There is also a growing awareness that combating discrimination requires structural safeguarding, including monitoring outcomes and timely adjustment of processes, to prevent indirect effects from leading to the structural exclusion of certain groups. Research participants have established special programs and teams to reduce the risk of discrimination. Almost all participants have appointed multidisciplinary project groups to address and mitigate this specific problem. Most participants have established policies for fulfilling the expectations, and some participants monitor their implementation. Adjustments and lessons learned from investigations are thereby secured in regular processes. Design and Scope Discrimination is often indirect and unconscious, and can arise as an unwanted side effect of process design. At the same time, discrimination is difficult to detect. The target groups involved file few complaints, and there are few objective standards.3 Thus, there are no simple solutions to perceive, detect, and prevent discrimination. Combating discrimination is a process requiring continuous vigilance and adjustment. This ongoing process is custom-made, and therefore it is even more important for this risk that companies retain control. The AFM research was therefore aimed at encouraging companies to professionally set up this process. For more information on the research methodology used, we refer to the appendix. (Experienced) discrimination by banks is often the result of process design aimed at reducing risks. Because discrimination often occurs indirectly, it is difficult for banks to detect. It is also difficult for people who are denied services or suffer from subpar service to determine whether this is the result of (indirect) discrimination. The risk of discrimination can result from banks implementing their gatekeeper role, where they give shape to the Money Laundering and Terrorist Financing Prevention Act (Wwft) and the Sanctions Act. In the research, we encouraged banks to adopt a broader scope and include all their service provision. Combating discrimination of their own employees is not in scope of the research, unless it has overlaps with customer discrimination. 3 Ipsos I&O Report, commissioned by the Ministry of Finance (2025): Experienced discrimination in service provision by banks and payment institutions

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 6 The AFM expects companies to proactively and independently combat (experienced) discrimination. To make it clear how banks combat discrimination in their service provision, the AFM uses a validated self-assessment. This method is designed to encourage banks to conduct self-analyses of their processes and the outcomes for customers. Based on five expectations regarding the safeguarding of customer interests (see Table 1), we ask banks to explain how they combat discrimination. The AFM then validates the banks' professionalism in combating discrimination based on evidence materials and an office visit. More information about the research methodology used is in the appendix. Table 1: Expectations

Expectation	Description
1	The board ensures a shared vision on combating discrimination
2	The company is set up to detect and effectively address discrimination
3	The organizational culture is aimed at combating discrimination
4	The company ensures appropriate communication during customer investigations
5	The company collects signals and complaints to prevent discrimination

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 7 Recommendations per Expectation Expectation 1. The board ensures a shared vision on combating discrimination Anchor combating discrimination in existing values. The bank's board is responsible for combating discrimination by the bank. This requires firmly connecting combating discrimination to the company's (existing) mission, vision, or strategy. For most banks, their documents (such as codes of conduct) already address customer interests, including vulnerable customers. They connect combating discrimination to existing corporate values. Give combating discrimination extra attention. Although customer interest was already part of all banks' core values, discrimination was a blind spot in the sector for a long time. Therefore, combating discrimination also requires extra attention. Leading companies use a broad definition of discrimination and pay special attention to indirect and unconscious discrimination. They have expanded the scope of the discrimination risk to the entire service provision, not just customer and transaction investigations in the context of their gatekeeper function. Top management is involved and connected to experts and stakeholders. At leading companies, top management is visibly involved for stakeholders inside and outside the bank. They seek advice from experts, advisory boards, and interest groups. They have actively sought contact with representatives of minority groups to understand how discrimination occurs and what its consequences are for these target groups. Expectation 2. The company is set up to detect and effectively address discrimination Define clear roles in combating discrimination. Banks have a clear division of roles. Not only the board, but also the first, second, and third lines have their own and appropriate role in combating discrimination. Many companies have already conducted thematic compliance investigations into possible discrimination. Approach combating discrimination programmatically. To combat discrimination, almost all research participants have established special programs and freed up personnel to further develop the organization on this topic. In almost all cases, these teams report the program's progress to the board. The organizational placement of these teams, and the background of the officials responsible for program execution, vary. Treat discrimination as a specific risk. The risk of discrimination is included in the non-financial risk management cycle, and the company takes appropriate mitigating measures. This includes attention to work processes and the employees who execute them. In particular, the risk of discrimination plays a role in the use of AI and automated decision-making. These technologies can adopt and reinforce existing inequalities, posing risks to equal treatment. As a result, banks see more dilemmas in practice, which are addressed in existing or new team structures, such as an ethics committee or in dilemma workshops.

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 8 Expectation 3. The organizational culture is aimed at combating discrimination Facilitate employees to combat customer discrimination. In discussions, we hear that executives have gone through a process where they learned to recognize the problem of discrimination by their bank. Initially, they saw discrimination as a consequence of individual behavior. Through investigations, internal evaluations, conversations, and training, they learned that discrimination can also be an unintended consequence of their own decisions and process design. This insight must also reach employees, and banks must actively work on this, for example by organizing awareness training. Banks must also ensure a safe environment where discrimination can be openly discussed. Finally, banks must have internal channels where employees can share their observations so that intervention can occur. Incorporate combating discrimination into existing codes. Almost all banks have a code of conduct and all employees take an oath. Discrimination is usually addressed here, but this is often limited to discrimination among colleagues. It also often concerns more direct forms of discrimination, meaning employees are not actively deployed to detect indirect discrimination to which they (unconsciously) contribute. Link your own diversity and inclusion policy to combating customer discrimination. All banks have diversity and inclusion policies, but just as diversity does not necessarily lead to inclusion, diversity also does not automatically eliminate blind spots for (indirect) discrimination in work execution. We see that leading banks explicitly link their own diversity and inclusion policy to customer treatment. Expectation 4. The company ensures appropriate communication during customer investigations Develop norms for appropriate communication. Customer investigation will always be part of executing the gatekeeper function, but communication with customers can be significantly improved. Banks, for example, adjust the language used in their letters and utilize experts to review the letters. They improve the language so communication becomes more accessible. They also change the tone of voice and address customers differently. Some banks state that they have shortened letters about customer investigations, while other banks indicate that clearer communication results in a longer letter. Be reachable for questions and feedback in a way that suits the target group. Communication also means the bank is reachable for questions and feedback. In correspondence, customers can find how they can easily contact the bank. Leading banks are open to feedback and continuously use it to improve their communication. The bank is also reachable if someone is not a customer, or cannot become a customer. Anchor combating discrimination in existing principles on customer interest. Banks have many guidelines for communication with customers, for example to comply with principles on centralizing customer interest. These principles can also be applied to communication about customer investigations. Leading banks have integrated combating discrimination into their principles on customer interest.

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 9 Expectation 5. The company collects signals and complaints to prevent discrimination Develop targeted policy for handling questions, reports, and complaints about discrimination. Banks explicitly categorize and register complaints about possible discrimination. Employees are trained to recognize discrimination and answer customer questions carefully. Most banks have adapted or supplemented their communication and complaint policy with definitions, identification, and work instructions for handling discrimination complaints. Actively collect complaints and signals. Research shows that people vulnerable to discrimination are less likely to file a complaint about it with their bank. Therefore, banks do not just wait for complaints, but also actively collect signals of possible discrimination. For this, leading banks are in contact with, for example, interest groups. Furthermore, some banks explicitly point out on their complaint page the possibility to report discrimination, including via an anonymous report to Landelijk Meldpunt Discriminatie.nl. Banks must also have a way to collect complaints if someone cannot become a customer at the bank as a result of discrimination. Periodically follow up on complaints and signals. Banks report periodically to the board on complaints and signals, with specific attention to possible discrimination. Findings lead to concrete improvement measures, with the progress and follow-up of these measures monitored. As a result, processes are adjusted.

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 10 Appendix: Research methodology with description of maturity levels The validated self-assessment is a method for supervising open norms using expectations and maturity levels. 4 This method is designed to stimulate professionalization without the AFM prescribing exactly what must happen. For the research, we established five expectations (see Table 1). Research participants self-assessed their maturity on each of these expectations, choosing from the levels 'ad hoc', 'documented', 'designed', 'monitored', and 'evaluated' (see Table 2). Subsequently, the participating banks motivated and substantiated their assessment with documents. The AFM validated these assessments based on an office visit and the documents. By mapping the maturity, the AFM increases insight into the self-regulatory capacity of companies and can adjust efforts if this falls short. The AFM held discussions with representatives of the participating banks after validating the assessed maturity levels. Prior to these discussions, we shared our observations with the participating banks. Subsequently, we asked the banks to reflect on our observations. They could indicate how they intend to give shape to the further professionalization of combating discrimination. In our ongoing supervision, we will discuss their progress on this. Table 1: Description of maturity levels

Level	Description	Examples of evidence
Ad hoc	• No policy5 for the expectation and it is not documented who is responsible for the expectation.
• Situations are resolved as they occur.
Documented	• It is documented who is responsible for the expectation.
• The policy for the expectation is not documented, but working methods and processes are generally executed in the same way.	• Job description
• Correspondence with agreements on tasks
Designed	• There is current policy for this expectation, and the policy has an owner.
• The company has documented for the expectation what it aims to achieve, the manner in which, the available resources, and the deadlines within which working methods are executed.	• Policy documents
• Procedure and process description
• Annual plan
Monitored	• Monitoring is established to gain insight into whether the policy is actually executed as intended.	• Monthly report
• Dashboard
• Action list
4 Van den Bergh & Mostert (2023) Supervision on exemplary behavior, counterargument, and self-reflection by the Dutch Financial Markets Authority. Van den Bergh et al. (2022) The AFM's perspective on culture.
5 The AFM uses a broad definition of policy. Policy is the operationalization of the strategy and is not necessarily related to laws and regulations.

© AFM 2026 | Combating Discrimination by Banks: From Insight to Action 11

Level	Description	Examples of evidence
• Monitoring is demonstrably discussed at the appropriate level.
• The company adjusts based on the outcomes.
Evaluated	• The policy for this expectation is structurally evaluated to determine whether the policy's intended goals are achieved.
• Attention is paid to the unintended and intended effects of the policy.
• Evaluations are demonstrably discussed at the appropriate level, and adequate follow-up is given to the evaluation outcomes.	• Evaluation
• Audit
• Advice