Evaluation of the DSI-AFM Covenant Final Report March 2026

Maarten Noordink, Frederique Uyterlinde, Ruben Pilon, Annemarijne Kaaij

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Table of Contents

1. Introduction 3.
2. Conclusions 7.
3. Recommendations 16.
4. Underlying Findings 19. A. Certification 20. B. DSI Public Register 25. C. Accreditation of Initial Training and Exams & PV Programs 29. D. Market 34. E. Organization and Funding 40. F. Supervision by AFM 44. Appendix: Consulted Sources 46. 2

1. Introduction

| Investment staff must demonstrably be professionally competent and can certify themselves through DSI.

Rules on Professional Competence

The European MiFID II directive stipulates that investment firms must meet requirements for the professional competence of employees. Employees who advise or provide information on investments, also referred to in the covenant that the AFM and DSI have concluded with each other as 'relevant persons', must demonstrate knowledge and skills. The European Securities and Markets Authority (ESMA) has drawn up guidelines for this, which have been incorporated in the Netherlands into the Professional Competence of Employees of Investment Firms Wft Regulation.

AFM Supervision

The Dutch Authority for the Financial Markets (AFM) monitors compliance with the requirements for professional competence. In 2017, the AFM concluded a covenant with DSI to secure the professional competence of investment professionals in the Netherlands. This covenant aimed to provide investment firms with a clear and practical way to demonstrate that their employees meet the statutory professional competence requirements, while simultaneously enabling the AFM to carry out supervision of compliance with these requirements more effectively and efficiently. With this, the AFM aims to contribute to maintaining and increasing the quality of investment services in the Netherlands and the confidence of the investing public in them.

DSI Certification

DSI is a foundation established in 1999 by the financial sector. DSI certifies professionals working in the financial sector on professional competence and integrity. DSI maintains 12 registers, including the 7 ESMA registers that fall within the scope of the covenant. Certification requires an exam and relevant work experience. Certified professionals follow the Permanent Professional Competence (PV) program annually at an accredited institute to maintain their certificate. DSI sets the final learning outcomes for training and exams. Certified professionals are included in a public register. A DSI registration is not mandatory. If firms do not opt for a DSI registration, they must demonstrate in another way that their employees who advise or provide information on investments are professionally competent. 4

| The AFM wishes to evaluate the functioning of the covenant with DSI in preparation for a possible new covenant.

Background

After nearly ten years of practical experience, the AFM wishes to evaluate the covenant with DSI, in view of possibly concluding a new covenant. The evaluation must show whether the covenant still meets current requirements and which improvements are necessary for a possible new covenant.

Objective of the Research

The evaluation aims to assess to what extent the covenant with DSI is an effective and efficient instrument for the AFM to secure the professional competence of 'relevant persons' in the securities sector, and which lessons can be taken from this for a potential new covenant.

Research Question

The research question for the evaluation is: To what extent is the covenant with DSI an effective and efficient instrument for the AFM to ensure that persons working in the securities sector ('relevant persons') demonstrably possess professional competence? The covenant is effective if its objectives are achieved with as few undesirable side effects as possible. Efficiency is present if the objectives are achieved with as few (financial) resources as possible and undesirable side effects, or if the maximum performance and effects are realized with the available resources. The objectives of the covenant have not been operationalized into measurable objectives. To be able to make a statement about effectiveness and efficiency, we base ourselves primarily on qualitative insights from available documentation and interviews.

Scope

In the research, we limit ourselves to the activities of DSI that relate to the certification and registration of investment staff in the ESMA registers. Other activities, such as disciplinary proceedings, fall outside the scope of the covenant and thus outside this research. 5

Guide to This Report

Chapter 2 of this report contains the conclusions. We then describe in Chapter 3 our recommendations for the AFM and DSI. Chapter 4 contains a comprehensive thematic overview of the underlying findings on which the conclusions and recommendations are based. An overview of consulted sources is included in the appendix.

| For the research, documents were studied, a self-evaluation was conducted, and 17 interviews were held.

Phase	Period	Research Activities
Scoping	June - August 2025	• Document study (see appendix for list of consulted documents)
• Exploratory interviews with the AFM and DSI
• Self-evaluation by DSI (factual and evaluative questions)
In-depth	September - November 2025	• 2 interviews with AFM: Asset Management and Retail Investing
• 3 group discussions at DSI: director and staff, Supervisory Board and members of DSI committees (accreditation committee, advisory committee Retail and advisory committee Institutional)
• 3 interviews with training providers
• 5 interviews with financial institutions – affiliated with DSI
• 1 interview with a financial institution – not affiliated with DSI
• 1 interview with a researcher in constitutional and administrative law at Vrije Universiteit
Analysis and Reporting	December 2025 – January 2026	• Discussion of draft findings with the AFM
• Verification of draft report for factual inaccuracies by DSI
• Discussion of draft report with the AFM
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2. Conclusions

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Main Conclusion

Overall, the covenant with DSI is an efficient and effective instrument within the risk-based supervision of the AFM (1). However, the certification system is vulnerable in parts (2) and its monitoring can be improved (3). 8 1.1 There is broad support among participating institutions for certification by DSI 1.2 The covenant contributes to the professional competence of professionals 1.3 DSI has noticeably improved its services, internal organization, and funding in recent years, with cooperation with participating institutions and training providers at the center 1.4 Alternatives do not necessarily lead to better outcomes 2.1 Free riding occurs to a considerable extent, which could put pressure on the system in the long term 2.2 Consolidation in the training market is a challenge 2.3 Training and exam offerings do not align with practice in several respects 3.1 There is (still) no current overview of market coverage 3.2 Free riding is a risk; the AFM and DSI have limited visibility on this 3.3 Customer satisfaction is not monitored systematically 3.4 Information exchange with training providers on exam-related matters is limited

1. The covenant with DSI is an efficient and effective instrument within the risk-based supervision of the AFM
2. The certification system is vulnerable in parts
3. Monitoring of vulnerabilities and risks is amenable to improvement

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Sub-conclusion 1 (1/3)

The covenant with DSI is an effective and efficient instrument within the risk-based supervision of the AFM

1.1 There is broad support among participating institutions for

certification by DSI Among participating institutions, there is broad support for certification by DSI, which is reflected, among other things, in a gradual increase in the number of certified professionals since 2023. Although exact data on the total target group (institutions and professionals) are currently unavailable, it is assumed that the majority of financial institutions, including all large and medium-sized parties, participate. The impression exists that participation is highest among advisors compared to employees who only provide information (see also conclusion 2.1). For participants, certification offers the main advantage that they can comply with compliance requirements for professional competence in an efficient manner. The attention the AFM pays to professional competence and the certification system acts as a stimulus. This has happened more recently, and DSI has observed the effect. We add the caveat that the willingness to cooperate with the research among institutions that do not have their employees certified by DSI was very limited. The perspective of this group therefore remains underrepresented, while it is expected that they would be more critical of the system.

1.2 The covenant contributes to the professional competence of professionals

To obtain and maintain a DSI certification, professionals must take an initial exam and update their knowledge and skills annually. Participating institutions are predominantly positive about the quality of the exams accredited by DSI, the associated training programs1, and the PV programs. Generally, there is a good balance between the effort invested and the learning outcomes. The quality of the exams and the PV programs is partly attributable to DSI's accreditation system. That system is robust, transparent, and aligned with the changing requirements of the investment sector. The accreditation system includes various quality safeguards, such as double testing, periodic revision of final learning outcomes, and interim updates of exams. There are also critical voices. For certain exams and programs, alignment with work practice is a point of attention. DSI acknowledges this and works with training providers on improvements. We will discuss this in more detail in sub-conclusion 2.3. Although there is room for improvement, perfect alignment with work practice should not be expected. Investment services are simply too diverse a field. Even with alternative models, alignment with work practice remains a challenge. For example, with the CDFD2, which can be compared to DSI to some extent, critical voices can also be heard from exam institutes and the sector regarding the final learning outcomes and assessment criteria, alignment with work practice, and assessment of skills.3 9

1. Although DSI does not accredit ESMA training programs, the (experienced) quality of training programs is an indicator of how the system works.
2. For financial advisors, a Wft diploma requirement applies. The College for the Competence of Financial Services (CDFD) was established by the Minister of Finance to develop the content of Wft exams and supervise exam institutes. The CDFD and DSI carry out partly comparable activities, with the key difference that the CDFD performs public tasks and DSI performs self-regulation.
3. KWINK group (2024). Evaluation of the College for the Competence of Financial Services (CDFD), Final Report.

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Sub-conclusion 1 (2/3)

The covenant with DSI is an effective and efficient instrument within the risk-based supervision of the AFM

1.3 DSI has noticeably improved its services, internal organization, and funding in recent years, with cooperation with participating institutions and training providers at the center

Between 2021 and 2024, a reorganization took place, during which changes were implemented in DSI's services, organization, and governance. Participating institutions state in interviews that services have improved since then. The certification system is transparent, and the (public) register is accurate and up-to-date. It is unknown how much the public register is used. Interview partners mention that specific groups consult the public register, such as wealthy private investors when selecting a qualified wealth manager and employers during recruitment procedures. There is some uncertainty regarding the term 'candidate-registered' in the register. The public register does not state why someone is registered as a candidate; this can have various reasons and does not necessarily mean that someone does not meet the professional competence requirements. We see that DSI has continuously sought further improvement in both its own services and the training and exam offerings in recent years. For this, DSI has established quality safeguards, including customer satisfaction surveys and evaluations. In recent years, cooperation with training providers and participating institutions has been intensified. DSI has a sound Administrative & Accounting Controls (AO/IC) system. In 2024, the accountant concluded that there is a system of AO/IC that is "generally adequately arranged," with "some details still open to improvement." DSI introduced a new funding system in 2024, making the annual participation costs more stable. This is seen as an improvement by participating institutions. That DSI supplements professional competence with integrity and some platform activities is not seen as a problem but rather as added value. There are no indications that the funding of the system by participating institutions conflicts with the independence of DSI and the quality of certification. 10

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Sub-conclusion 1 (3/3)

The covenant with DSI is an effective and efficient instrument within the risk-based supervision of the AFM

1.4 Alternatives do not necessarily lead to better outcomes

Alternatives to a covenant have advantages and disadvantages. There is no alternative that can be stated with certainty to lead to better outcomes. Terminating the covenant: The AFM can terminate the covenant and cooperation with DSI. This choice would have consequences for both the AFM itself and DSI. Terminating the covenant is expected to lead to a decrease in participation in DSI certification. The covenant and the authority of the AFM are now key motivators for participants. Without the covenant, more financial institutions will give their own interpretation to the requirements regarding professional competence. Support and participation in the system will decline, meaning costs must be borne by fewer participants, and the system could fall into a downward spiral. For small and medium-sized institutions, organizing professional competence themselves means extra administrative and organizational burden, as they must demonstrate that their employees meet the required qualifications. There is a risk that attention to professional competence within these organizations will decrease. Furthermore, the disappearance of the covenant could lead to the emergence of various competing certification systems. This causes market fragmentation, meaning there is no longer a clear standard for professional competence and integrity. This means that the AFM can no longer rely significantly on DSI's register in its supervision of professional competence. Instead, the AFM will have to check more frequently or intensively whether institutions comply with statutory requirements. This could take the form of its own registration, periodic checks at institutions, or requesting exam results from training providers. Regardless of the chosen form, the AFM will face a greater supervisory burden. Diploma requirement: A diploma requirement, similar to that for financial advisors, would mean that companies are required to demonstrate that their employees hold the required diplomas. This would very likely lead to greater participation in exams and facilitate supervision by the AFM. At the same time, this shifts responsibility to the government to ensure a sufficiently high-quality supply of training and exams, meaning the organization(s) responsible for this – which could be DSI, but also another organization – would acquire public tasks. Furthermore, the organization would likely play a larger role in (self) drafting exam questions and supervising exam locations and training/exam institutes. This makes the system more robust, but possibly also more formal, extensive, and expensive than the current model. There would no longer be self-regulation, which could lead to less support and ownership within the sector. The public tasks are limited to the ESMA professional competence requirements, but these can be combined with private tasks. In the case of DSI, this involves the non-ESMA registers and activities regarding integrity. Such a combination of public and private tasks occurs more frequently, for example with the Dutch Bar Association (NOvA) and the Royal Notarial Profession Organization (KNB). These are public law professional organizations that combine public tasks, including managing a register, with private activities in the field of interest representation and support for the professional group. A statutory obligation to register employees at DSI: Similar considerations apply to this alternative as to a diploma requirement. Participation in the ESMA registers would increase and supervision by the AFM would become easier. However, register management would become a public task, which could be combined with private tasks, with all the aforementioned advantages and disadvantages. The model would likely become more robust, but also more formal, extensive, and expensive. 11

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Sub-conclusion 2 (1/2)

The certification system is vulnerable in parts

2.1 Free riding occurs to a considerable extent, which could put pressure on the system in the long term

There is a considerable degree of free riding. Various financial institutions make use of the training programs accredited by DSI, but do not have all their employees (fully) certified. How often this occurs is not precisely known; data on this were still missing at the time this research was conducted. The AFM has, however, begun collecting more information on this from investment firms in 2025. Initial insights from this indeed point to a considerable degree of free riding. That free riding occurs is also clearly evident from the interviews conducted for this research. Data on participation in accredited training programs also provide clear indication. The reasons for free riding vary. Some institutions express support for the system but find the added value of certification limited for certain types of employees. This applies mainly to employees who only inform customers and do not advise. Advisors generally have more customer contact and visibility, making certification and public registration more important for this group. Other institutions are not aware that they are not or only partially contributing to the system. They require employees to follow the accredited training programs but leave the choice to get certified to the employee themselves. There are also institutions that are explicitly critical of the system and do not have their employees certified, but still make use of the accredited training programs because it is an easy way to remain compliant. The evaluation does not show that including integrity in DSI certifications is a decisive reason for financial institutions not to have employees certified. In several interviews, financial institutions mentioned that even employees who are not certified by DSI undergo integrity training. Free riding does not currently cause problems for DSI, as costs can be covered by current revenues. Due to the increase in the number of certified professionals and a reorganization, costs per participant have remained stable in recent years. Nevertheless, it remains important to monitor the extent of free riding, and the reasons why institutions choose it, and to adjust if necessary (see 3.2). Primarily because free riding means the AFM must make greater efforts to gain good and complete visibility on compliance with professional competence requirements by the sector. This comes at the expense of supervisory efficiency. Secondly, because free riding could put financial stability of DSI under pressure in the future. If market developments or choices by financial institutions lead to a decrease in the number of certified professionals, costs per participant will rise, making certification less attractive. This could lead to a vicious circle in which ultimately too few participants remain and DSI services become unaffordable. 12

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Sub-conclusion 2 (2/2)

The certification system is vulnerable in parts

2.2 Consolidation in the training market is a challenge

The training market consists of a limited number of providers. This can have negative consequences for the quality and availability of training programs. For four of the seven ESMA registers, there is only one provider. This concentration increases dependence on a few training providers and reduces choice for professionals. At the same time, larger providers can more easily keep pace with developments such as digitalization. DSI monitors the training market and maintains contact with training providers regarding the quality and quantity of the training offering.

2.3 Training and exam offerings do not align with practice in several respects

Training programs align better with practice in retail than in institutional. This is because institutional functions are generally more specialized. The added value of a training program is also less, because institutional professionals already hold other qualifications (such as CFA) and naturally pay considerable attention to professional competence because their professional clients expect it. DSI acknowledges this situation and works with training providers to align the offering with demand. The existing shortened assessments for relevant prior qualifications such as CFA level 3 or VBA are an example of this. Furthermore, following a training program is not mandatory. Professionals who have already completed another training program or have acquired knowledge themselves can also take only the exam. While the quality of the initial exams is generally considered high, there are doubts about the quality of some PV programs. Differences are perceived in level and intensity between training providers: for some, PV is offered only once, while others offer it throughout the year. This is partly due to the current system with relatively general learning objectives for PV. DSI acknowledges this and, following a recent evaluation, has set a new minimum for PV intensity from 2026. Skills exams are generally considered less valuable than knowledge exams: the level is lower and skills