AFM Agenda 2026

Integrity and criminal behavior
Sustainability
Digitalization
Internationalization
General developments
AGENDA ACCOUNTABILITY
JANUARY 2026
AFM Agenda 2026
In brief Digitalization, geopolitical uncertainty, sustainability, and integrity continue to strongly influence the financial sector and the AFM's supervision. In 2026, we focus, among other things, on careful communication regarding the pension transition, responsible use of data and AI, better protection of consumers in the credit market, and strengthening digital resilience. Additionally, we work on robust risk management for asset managers, higher quality of audit controls, and combating fraud, money laundering, and deception, also in the crypto market. These priorities form the core of our supervision in 2026.

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1. Key developments 3
2. Strategy 4
3. Priorities and key activities 2026 5
   3.1 Supervision of financial services 8
   3.2 Supervision of capital markets 13
   3.3 Supervision of Asset Management 17
   3.4 Supervision of accounting and reporting 21
   3.5 AFM-wide topics 25
   3.5.1 Combating criminal behavior 25
   3.5.2 Financial stability 26
   3.5.3 Strengthening the professional organization 27
4. Finances 2026 29
5. Annex: KPIs 37
   Table of Contents

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In our publication Trendzicht, the AFM provides an overview of the most important trends and risks in the financial sector. By seeing and understanding changes in the sector in good time, we ensure a supervisory approach that addresses risks early, looks ahead, and prevents problems from arising. Below is a summary of the trends that play a central role in drawing up the AFM Agenda 2026. General developments Digitalization Sustainability Internationalization and European legislation

• Geopolitical tensions can pave the way for a more fragmented global financial system.
• Markets for crypto and stablecoins are gaining influence and the importance of private markets is increasing.
• Rising government debts are putting pressure on sustainable economic growth and capital market stability.
• The application of AI in the financial sector seems to be accelerating further.
• Due to geopolitical tensions, discomfort regarding digital dependencies on non-European service providers has increased.
• Increasing digitalization requires continued attention to cybersecurity in the financial sector, also given the current geopolitical situation.
• The economic risks of climate change are increasing and emphasize the importance of the sustainability transition.
• The more negative sentiment regarding sustainability is putting pressure on the approach to climate risks and thereby increasing risks for the financial sector in the long term.
• Hardened international political relations complicate the creation of global agreements and rules.
• Within Europe, work is underway to simplify and modernize (financial) legislation.
• With the establishment of AMLA, European cooperation in combating money laundering and terrorism financing has intensified.
  Integrity and criminal behavior
• AI and "crime-as-a-service" are catalysts for digitized crime and require a coordinated, international response.
• Crypto service providers are exposed to high risks of money laundering, terrorism financing, and circumventing sanctions.
  TREND MAP

1. Key developments

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2. Strategy
The AFM's mission provides direction for the execution of our statutory tasks: 'The AFM advocates for fair and transparent financial markets. As an independent behavioral supervisor, we contribute to sustainable financial well-being in the Netherlands.' The AFM Strategy 2023-2026, like previous years, forms the starting point for the AFM Agenda 2026. This strategy is summarized in the figure below. The AFM advocates for fair and transparent financial markets. As an independent behavioral supervisor, we contribute to sustainable financial well-being in the Netherlands. We work risk-driven, data-driven, and result-oriented. Professional organization: an agile and learning organization, an attractive employer, with well-functioning IT. Financial services Customer interest central in times of transition. Capital markets Integrity trading behavior and robust transparent markets. Asset management A robust and agile asset manage- ment sector. Accounting and reporting Reliable and relevant (non-) financial information provision. Digitalization, internationalization and sustainability provide direction for our work. AFM Strategy House The AFM's supervisory approach is risk-driven, data-driven, and result-oriented:

• Risk-driven means that the AFM focuses on matters where the most damage can occur for consumers, investors, and other market parties. This approach helps us make sharper choices and deploy available supervisory resources targeted.
• Data-driven means that we support our supervision as much as possible with data: we collect, open up, and analyze information to understand, follow, and address risks.
• Result-oriented means that we strive for maximum impact with our resources, responding to behavior and underlying causes.
  In the AFM Strategy 2023-2026, we identified three important trends that are decisive for society, the financial sector, and the AFM itself: digitalization, internationalization, and sustainability. These trends remain directional for our supervision and policy development in 2026. The previous chapter described how these developments translate into the trend map this year; the full analysis can be found in Trendzicht 2026. The mission and external developments have been translated into the key supervisory objectives for the four supervisory areas. These have been elaborated in Chapter 3 for the coming year. Additionally, AFM-wide topics, such as combating criminal behavior and financial stability, are elaborated in Chapter 3.5. A professional organization provides a solid foundation for achieving supervisory objectives and the mission. The objectives in this area can be found in Chapter 3.5.3. Input from the sector was also taken into account when drawing up the agenda, including signals regarding risks and societal developments. Strategic goals have been formulated in broad terms, which are translated step-by-step within the organization into concrete supervisory activities and project plans.

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3. Priorities and key activities 2026
Based on the key developments and the AFM Strategy 2023–2026, the AFM has established its overarching objectives for 2026. Below is an overview of the key priorities, which are then explained further per sub-area. The agenda emphasizes new activities, in addition to existing work that the AFM continues unabated. 3 Asset management 3.3.1 Strengthen resilience asset managers 3.3.2 Protect against cyber attacks 3.3.3 Monitor AI use asset managers 3.3.4 Test sustainability claims 5 AFM-wide supervisory topics 1 Financial services 3.1.1 Supervise pension transition 3.1.2 Put customer interest at the center 3.1.4 Implement data-driven supervisory strategy 3.1.3 Protection consumer credit market 2 Capital markets 3.2.1 Strengthen digital resilience 3.2.2 Address market abuse 3.2.3 Strengthen capital market chain Quality of audit and reporting 3.4.1 Targeted learning from mistakes 3.4.2 Increase fraud detection 3.4.3 Implementation Periodic Quality Assessments 4 AI Combat investment fraud Protect crypto investors Increase Anti-money laundering supervision International supervisory approach Clarify sustainability rules The AFM-wide supervisory topics have a broad and organization-crossing character, so they are integrated horizontally into the different supervisory chapters
3.5.1 3.5.1
This number refers to the place where this priority is further explained

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Financial services:

• The AFM emphasizes the importance that participants are included in time regarding what the pension transition means for them personally. The AFM ensures that pension administrators provide correct, clear, balanced, and timely information to participants. We do this by risk-drivenly checking transition communication to participants and providing guidance.
• The AFM ensures that customer interest remains central in the use of new technologies, such as generative AI. We do this by paying close attention to how products and services become increasingly personalized and ensuring that data and technology are used responsibly by financial enterprises.
• The AFM ensures that consumers remain well protected in the changing credit market. We do this by supervising new parties, investigating how data is used in granting credit, and checking automated credit acceptance systems.
• The AFM increases the quality and accessibility of independent advice through a data-driven supervisory strategy. Thus, we stimulate initiatives that contribute to the financial health of consumers.
  Capital markets:
• The AFM stimulates the digital resilience of financial infrastructure by strengthening the resilience of market parties against digital and physical attacks and by keeping their dependence on IT services and data better manageable.
• The AFM tackles market abuse using AI by critically assessing unreliable information and AI-driven sources, and by intervening in opaque or uncontrolled trading behavior of self-learning and autonomous AI systems.
• The AFM helps the financial system better withstand (geopolitical) uncertainties. We do this by strengthening the capital market chain, for example, by helping market parties improve their risk management.
  Asset management:
• The AFM strengthens the resilience and control measures of asset managers by supervising them and conducting targeted investigations into their risk management and control measures.
• The AFM investigates how asset managers use digital technology to protect themselves against cyberattacks and prevent the failure of their IT systems.
• The AFM investigates the use of AI applications and the design of risk management by asset managers based on a market-wide exploration.
• The AFM focuses on fair and transparent sustainability information by testing sustainability claims of asset managers and supervising the use of sustainability terms in fund names.
  Quality of audit and reporting:
• The AFM strengthens the culture of accounting organizations by encouraging them to learn targeted from mistakes and to conduct independent root cause analyses.
• The AFM strengthens the positive trend in fraud detection by accounting organizations and promotes that they signal the risk of discontinuity earlier.
• The AFM implements the Periodic Quality Assessments by setting up an efficient and risk-based assessment process for all accounting organizations.
  AFM-wide supervisory topics:
• The AFM combats investment fraud by strengthening cooperation with banks, tackling parties that facilitate fraud, carrying out digital interventions, and warning through information campaigns.
• The AFM better protects crypto investors by supervising how crypto service providers offer their services, provide information, and organize their operations. The AFM targetedly addresses risky and non-integrity behavior, such as pump & dumps and scams.

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• The AFM focuses on anti-money laundering supervision that is risk-oriented and has clear, effective rules so that institutions adequately combat money laundering. We are preparing for the new European package against money laundering and terrorism financing (AML/CFT) and actively contributing to the design of new legislation by the new supervisor AMLA.
• The AFM continues to advocate for clear sustainability rules. It checks at issuing institutions whether sustainability reports are drawn up according to the law and stimulates accounting organizations to be well prepared to provide assurance (assurance) on these reports.
• The AFM steers internationally towards a risk-driven, data-driven, and result-oriented supervisory approach, further supervisory convergence, and a level playing field in Europe. We do this by participating in international working groups and contributing to international policy discussions.

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3.1 Supervision of financial services
Customer interest central in times of transition.
As a behavioral supervisor, the AFM contributes to financial well-being in the Netherlands. Developments in the fields of digitalization, the reform of the pension system, and the sustainability of society influence the financial well-being of consumers. In this light, it is important that financial service providers continue to place customer interest at the center when offering financial products and services. This means, among other things, that pension administrators inform their participants timely, balanced, clearly, and correctly about the transition to the new pension system. The application of new technologies, such as generative AI, offers both opportunities and risks for institutions and consumers. To limit these risks, a continuous focus on customer interest is important. Furthermore, the changing credit market requires supervision of new parties and the responsible use of technology and data in the credit acceptance process. The goal is that consumers are less affected by mistakes in the acceptance process, over-indebtedness is prevented, and consumers with debt arrears are treated equally and given perspective on a debt-free future. Finally, the AFM focuses on strengthening the quality and accessibility of independent financial advice, so that advisors and intermediaries know their obligations and responsibilities and act in the interest of the customer. In 2026, we want to achieve the following with supervision of financial services:
Transition overviews of pension administrators that have been implemented at the end of 2025 and/or in 2026 are risk-drivenly assessed and provided with feedback. New insights and guidance are shared across the sector. The compliance investigation into choice guidance is completed and findings are shared across the sector. These insights help pension administrators in executing adequate choice guidance and enable participants to make suitable choices. We develop an effective way of supervising the use of artificial intelligence (AI) in the financial sector. We do this by conducting research and pilots, training employees in recognizing and assessing AI applications, and hiring new colleagues with technological expertise. This ensures that we, as supervisors, are well prepared for the opportunities AND risks of AI. We have a better overview of new parties in the credit market. Think of companies that manage loans (credit servicers) and providers of "Buy Now, Pay Later" products (BNPL). We ensure they have the correct licenses and supervise how they operate. Additionally, we investigate how the use of data and automatic systems in assessing credit applications affects the quality of loans. Thus, the AFM ensures that consumers remain well protected in the changing credit market. We strengthen supervision of financial service providers and mortgage advice with a data-driven approach. Parties ensure controlled and honest business operations and meet licensing requirements, while a significant number are able to further improve the quality of their advice.

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3.1.1 Priority 1: Pension administrators must provide timely,
balanced, clear, and correct transition communication.
What is in the Strategy 2023-2026?
To make the complex transition to the new pension system careful and understandable for participants and pension administrators, the AFM remains in close contact with the pension sector. It provides clarity on the application of new rules, gives guidance, shares good examples, and uses data to follow developments. This allows risks to be assessed better and ensures effective and appropriate supervision. What do we want to achieve in 2026? We are in contact with the pension sector and contribute to careful participant communication during the pension transition. Additionally, we focus on choice guidance and provide good examples via, among others, the AFM Transition Bulletin, roundtable discussions, and presentations. These insights help pension administrators in executing adequate choice guidance and enable participants to make suitable choices. Which activities contribute to this?

• In 2026, we continue with the assessment of pension administrators' communication plans and focus on prior influence through more contact moments with pension administrators and umbrella organizations. We also conduct risk-driven supervision of participant communication. The goal is that pension administrators think in time about how they include their participants in the pension transition.
• We conduct research into how implemented funds inform their participants about the collective payout phase.
• As a follow-up to the 2025 research, we investigate how pension administrators guide participants in making existing choices regarding retirement. Adequate choice guidance must limit the risk of non-suitable choices — with possibly unwanted financial consequences.
• Discussions are held with pension funds, pension insurers, premium pension institutions, industry associations, the Ministry of Social Affairs and Employment (SZW), and De Nederlandsche Bank (DNB). These discussions take place, among other things, through individual consultations with pension administrators, participation in congresses, and organizing roundtable discussions. Additionally, the AFM organizes the Pension Event 2026 and publishes the AFM transition bulletin. The goal of these activities is to convey the message about participant communication during the pension transition even more effectively. That message is that participant communication must be timely, correct, balanced, and clear.
  3.1.2 Priority 2: Customer interest remains central in the use of new technologies, such as
  generative AI.
  What is in the Strategy 2023-2026?
  The AFM supervises providers of digital financial products, especially when offered via low-threshold apps. Digital marketing targeting consumers for whom these products are not suitable also receives our priority. The financial sector must use data and technology responsibly. We therefore stimulate institutions to handle AI and other innovative applications carefully. Additionally, we ask for transparency and explainability in the use of customer data and algorithms. We therefore ensure that institutions adjust their business operations and risk management in time to new rules, such as the rules in the European AI Act. What do we want to achieve in 2026? We develop an effective supervisory approach for the application of new technologies, in particular AI. Through in-depth research, pilots, targeted training, and attracting employees with relevant expertise, we gain broad insight into the use of AI within the financial sector. Additionally, we use (new) technologies ourselves to strengthen our supervision.

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Which activities contribute to this?

• With a view to effective supervision of the AI Act, we develop an integrated supervisory approach.
• To gain better insight into technological developments within the insurance sector, we map the ongoing digitalization. Additionally, we investigate how insurers use AI.
• Research into existing and emerging AI applications at pension funds and pension administration organizations aimed at improving customer interaction, communication, and/or information provision. The goal is to map which applications are relevant for the pension sector and how they can contribute to increasing pension awareness and trust.
• Research into the use of AI by a party in the credit lending chain and into the degree of hyper-personalization in financial services. In this way, knowledge and skills are acquired to be able to supervise the use of AI.
• We are building an application to collect risky online advertisements and automatically assign them a risk score. Supervision of information provision by financial enterprises becomes more efficient and effective through this. A tool is also being built to periodically collect information via web scraping on the degree of transparency regarding the sustainability of investment products. This information on sustainability is assessed based on the Regulation on sustainability disclosure in the financial services sector (SFDR).
  3.1.3 Priority 3: Consumers remain well protected in the
  changing credit market.
  What is in the Strategy 2023-2026?
  Consumers can borrow online more easily, which increases risks of problematic debts. The AFM supervises this closely. At the same time, new mortgage forms are emerging due to trends such as sustainability and aging. Some of these innovations bring risks. The AFM continues to ensure that lending standards are applied responsibly and intervenes where necessary. What do we want to achieve in 2026? Our supervision focuses on licensing new parties coming under supervision, such as credit service providers and BNPL providers. Additionally, we investigate the outcomes and design of automated credit acceptance processes and the increasing use of data in granting credit. Which activities contribute to this?
• Realizing a supervisory approach for a robust credit acceptance process in the mortgage chain. The goal is that fewer consumers are affected by mistakes, because financial enterprises prevent them better, signal them faster, and restore them in time.
• With the entry into force of the Consumer Credit Directive 2 (CCD2), the standards for credit providers are adjusted and expanded. More a