Combating Discrimination by Banks: From Insight to Action

REPORT ANALYSIS
Combating Discrimination by Banks: From Insight to Action

In brief: Combating discrimination in financial services aligns with what the AFM does: working towards fair and transparent markets and contributing to sustainable financial well-being. This includes businesses that actively fight discrimination in their services. Our research into how some major banks combat discrimination provides the entire sector with tools for (further) strengthening their anti-discrimination approach.

MAY | 2026

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

Foreword
The Authority for the Financial Markets (AFM) sees combating discrimination as an important societal task and feels responsible for contributing to it. As an independent behavioral 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 fits its mission. Financial companies can use these recommendations to strengthen their approach against discrimination.

Introduction
Background and Objective
People (especially people 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. Combating money laundering risks can lead to specific customer groups not having access to products and services that others do have access to. Additionally, they may face excessive control and discrimination in service provision. Discrimination is prohibited by law, and the societal interest in combating discrimination is great. The Authority for the Financial Markets (AFM) supervises the safeguarding of customer interest by financial companies in the provision of financial products and services based on the Financial Supervision Act (Wft). Additionally, the AFM oversees orderly and honest business operations, including customer acceptance and selection policies. Customer interest is under pressure when companies have to make trade-offs between different interests. Generally, in behavioral supervision, we see that commercial pressure can lead to violations of customer interest. In the case of discrimination, combating risks can also lead to violations of customer interest. The AFM and De Nederlandsche Bank (DNB) have jointly launched projects with the goal of combating discrimination. 1 2 Where processes aimed at combating money laundering and terrorist financing affect customer interest, there is an overlap between the supervision of the AFM and DNB. The AFM and DNB have therefore conducted research to give banks insight into the progress they are making 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 at five banks since September 2025 into how they combat discrimination against customers, the results of which are 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 tools for improvements that have been applied by participants in the research. Based on the research results, we have created an overview of the main recommendations. We encourage all banks to use the recommendations from 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 participants in the research. Sustained improvement requires relentless attention to combating discrimination. Additionally, the AFM will conduct research in the future with financial companies that have not yet participated. 1 DNB Report (2024): Combating Discrimination by Banks in Compliance with the Wwft 2 DNB Report (2025): Consciously Combating
Discrimination - Managing the Risk of Discrimination in Compliance with the Wwft and the Sw

Key Findings
The AFM sees that participants in the research share constructively and openly what they are doing to combat discrimination. All participants in the research now recognize the problem of experienced discrimination in their services. In the discussions, most participants describe that recognizing discrimination took time. With the insights gained, they have proactively started implementing improvements.
Most companies now adopt a broader perspective on discrimination than a few years ago. From the discussions, it appears 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 combating financial crime, these are now often rolled out more broadly within the company. Additionally, participants recognize that discrimination can be an unintended consequence of interpretations and working methods, and that discrimination can also occur indirectly if distinction is made on other characteristics in a process. There is a growing awareness that combating discrimination requires structural safeguarding, including monitoring outcomes and timely adjustment of processes, to prevent indirect effects from leading to structural exclusion of certain groups. Participants in the research 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 the implementation thereof. 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 the design of processes. At the same time, discrimination is difficult to detect. The target groups involved file few complaints, and there are few objective standards.3 There are thus no simple solutions to perceive discrimination, and subsequently detect and prevent it. Combating discrimination is a process that requires continuous vigilance and adjustment. This continuous process is custom-made, and therefore it is even more important for this risk that the management remains with the companies. The AFM research was therefore aimed at encouraging companies to professionally set up this process. For more information about the research methodology used, we refer to the appendix. (Experienced) discrimination by banks is often the result of the design of processes aimed at reducing risks. Because discrimination often arises indirectly, it is difficult for banks to detect. Also for people who are denied services or suffer from mediocre service provision, it is difficult to determine if that is the result of (indirect) discrimination. The risk of discrimination can be the result of the implementation of the gatekeeper role by banks, 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 services. Combating discrimination of own employees is not in scope of the research, unless it has overlaps with discrimination of customers. 3 Ipsos I&O Report, commissioned by the Ministry of Finance (2025): Experienced Discrimination in Service Provision by Banks and Payment Institutions

The AFM expects companies to be motivated and independent in combating (experienced) discrimination. To make it clear how banks combat discrimination in their services, the AFM uses a validated self-assessment. This method is aimed at encouraging banks to conduct their own analyses of their processes and the outcomes for customers. Based on five expectations regarding the safeguarding of customer interest (see Table 1), we ask banks to explain how they combat discrimination. The AFM then validates the professionalism of the banks 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

Recommendations per Expectation

Expectation 1. The Board ensures a shared vision on combating discrimination Anchor combating discrimination in existing values. The board of the bank is responsible for combating discrimination by the bank. For this, it is necessary to firmly connect combating discrimination to the (existing) mission, vision, or strategy of the company. For most banks, it applies that they already paid attention to customer interest, including vulnerable customers, in their documents (such as the code of conduct). They connect combating discrimination to existing corporate values. Give combating discrimination extra attention. Although customer interest was already part of the core values of all banks, discrimination has long been a blind spot in the sector. Therefore, combating discrimination also requires extra attention. Leading companies use a broad definition of discrimination and have special attention for indirect and unconscious discrimination. They have expanded the scope of the risk of discrimination to the entire service provision, and not only customer and transaction investigations in the context of their gatekeeper function. The top management is involved and connected to experts and stakeholders. From companies that are leading, the top management is visibly involved for stakeholders inside and outside the bank. They let themselves be advised by experts, advisory boards, and interest groups. They have actively sought contact with representatives of minority groups to understand how discrimination arises, and what the 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.
Address combating discrimination programmatically. To combat discrimination, almost all participants in the research have established special programs, and released people to further develop the organization on this theme. These teams report the progress of the program to the board in almost all cases. The organizational structure of these teams, and the background of the officials responsible for implementing the program, vary. Treat discrimination as a specific risk. In the non-financial risk management cycle, the risk of discrimination is included, and the company takes appropriate mitigating measures. This includes attention for 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, with risks for equal treatment. As a result, banks see more dilemmas in practice, which are treated in existing or new team structures, such as an ethics committee or in dilemma workshops.

Expectation 3. The organizational culture is aimed at combating discrimination Facilitate employees to combat discrimination of customers. In the discussions, we hear that the executives have gone through a process in which 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, discussions, and training, they learned that discrimination can also be an unintended consequence of their own decisions and the design of processes. 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 in which 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. Usually, there is also attention for discrimination here, but this is often limited to discrimination of 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. Connect own diversity and inclusion policy to combating discrimination of customers. All banks have diversity and inclusion policies, but just as diversity does not necessarily lead to inclusion, diversity also does not automatically lead to removing blind spots for (indirect) discrimination in the execution of work. We see that leading banks make an explicit connection between their own diversity and inclusion policy and 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 of their letters, and use experts to revise the letters. They improve the language so that communication becomes more accessible. They also change the tone of voice, and address customers differently. Some banks state that they have shortened letters regarding customer investigations, while other banks state that clearer communication results in a longer letter. Be reachable for questions and feedback in a way that fits the target group. Communication also means that 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 use this continuously for the improvement of 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 placing customer interest centrally. These principles can also be applied to communication about customer investigations. Leading banks have integrated combating discrimination into their principles on customer interest.

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 adjusted 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 who are vulnerable to discrimination are less likely to file a complaint about this 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. Additionally, some banks explicitly point out on their complaint page the possibility to report discrimination, including via an anonymous report at 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, where the progress and follow-up of these measures are monitored. As a result of this, processes are adjusted.

Appendix: Research methodology with description of maturity levels
The validated self-assessment is a method for supervision of open norms using expectations and maturity levels.
4 This method is intended to stimulate professionalization without the AFM prescribing exactly what must happen. For the research, we established five expectations (see Table 1). Participants in the research assessed their maturity on each of these expectations themselves, where they could choose 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-regulating 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. Here, they could indicate themselves how they will give shape to the further professionalization of combating discrimination. In our ongoing supervision, we will discuss the progress thereof with them.

Table 1: Description of Maturity Levels
Level Description Examples of Evidence
Ad hoc • There is no policy5 for the expectation and it is not recorded who is responsible for the expectation.

Situations are solved as they occur.
Documented • It is recorded who is responsible for the expectation.
The policy for the expectation is not recorded, but working methods and processes are generally executed in the same way.
Job profile
Correspondence with agreements on tasks
Designed • There is current policy for this expectation, and the policy has an owner.
The company has recorded for the expectation what it aims for, the manner in which, the resources available, and the deadlines within which the 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 of exemplary behavior, counter-argumentation and self-reflection by the Authority for the Financial Markets. Van den Bergh et al. (2022) The perspective of the AFM 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.

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 if the intended goals of the policy are achieved.
There is attention for the unintended and intended effects of the policy.
Evaluations are demonstrably discussed at the appropriate level, and adequate follow-up is given to the outcomes of the evaluation.
Evaluation
Audit
Advice

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