2026-04-09
The AFM has published updated Mortgage Advisory Guidelines that require financial advisors to maintain an independent professional role, critically evaluate client requests, and apply proportionality to tailor the depth of their work to each unique situation. The revision introduces new mandatory sections on sustainability and relationship termination, while placing stronger emphasis on probing for contradictions and explicitly documenting assumptions when client data is incomplete. By positioning the guideline as a professional tool rather than a checklist, the AFM aims to ensure consumers can reliably trust suitable mortgage advice, with ongoing supervision and market monitoring to verify compliance.
News
09/04/26
The independent role of the advisor as a starting point. Greater emphasis on probing for contradictions. And sustainability and relationship termination as new themes. These are the main points from the updated Mortgage Advisory Guidelines. The guideline assists mortgage advisors and provides tools to advise consumers suitably on mortgage credit.
In brief
The independent role of the advisor as a starting point of the new guideline
Greater emphasis on probing for contradictions and on proportionality
Sustainability and relationship termination as new themes
Consumers must be able to trust suitable mortgage advice; the AFM will continue to supervise this
The independent role of the advisor as a starting point of the new guideline The guideline more strongly emphasizes that the financial advisor has an independent role as a professional. The advisor is therefore expected not to be guided solely by customer wishes. Instead, they must critically weigh these wishes and provide a substantiated recommendation on what fits the customer's personal situation. This aligns with the advisory standard under Article 4:23 of the Wft and with calls from the market to give advisors sufficient professional discretion.
Greater emphasis on probing for contradictions and on proportionality The guideline covers the entire advisory process – from initial contact to aftercare. New is the extra emphasis on probing further when contradictions arise, and on explicitly stating assumptions when data is incomplete. The guideline provides direction and clarity on how advisors can meet the statutory advisory standard. The guideline is a tool for advisors, not a checklist. The principle of proportionality is central; the advisor adjusts the depth of their work to the unique customer situation.
Sustainability and relationship termination as new themes At the request of the market, sustainability and relationship termination have been added. This is because both topics have now become part of mortgage advice. Under 'sustainability', it describes how advisors can help consumers map out sustainability options, financing possibilities, and potential financial consequences. Under 'relationship termination', it addresses the importance of the advisor clearly discussing potential risks, so that customers understand what personal consequences this may have for them.
Consumers must be able to trust suitable mortgage advice; the AFM will continue to supervise this A draft version of the guideline was previously published for consultation . In total, we received 23 responses. The feedback statement outlines how we have incorporated the responses into the final text of the guideline. With the publication of the new guideline, we are responding to the sector's need to update the previous version and aim to contribute to higher quality mortgage advice in the market. We remain in dialogue with market parties regarding the application of the guidelines and monitor whether consumers can actually rely on suitable advice.
Tags
Advisors, intermediaries & authorized representatives
Banks
More information
AFM Mortgage Advisory Guidelines 2026 (pdf, 684 kB)
AFM Feedback statement mortgage advice (pdf, 163 kB)
AFM Responses to consultation Mortgage Advisory Guidelines (pdf, 634 kB)
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