DNB applies proportionality to recovery plans of small and medium-sized banks

Factsheet

Read aloud

Every small and medium-sized bank (less significant institution – LSI) must have a recovery plan approved by DNB. European rules prescribe both its content and submission frequency. With a view to proportionality, DNB has the option to simplify these obligations for certain LSIs.

Published: 23 August 2023

Each year, DNB conducts an eligibility assessment to determine whether LSIs qualify for simplified recovery plan obligations. In doing so, we consider both quantitative and qualitative criteria, in line with Commission Delegated Regulation 2019/348. For the quantitative criteria, we calculate a score expressed in basis points for each bank. DNB has decided to set the threshold at 105 basis points, meaning that banks with a score above this threshold are not eligible for simplified obligations. We then apply qualitative criteria to banks with scores below the threshold. This means that banks which the ECB qualifies as high-impact and banks that will be taken into resolution in case of failure are not eligible for simplified obligations. The remaining banks qualify for simplified obligations and will be informed about this each year.

Simplified obligations relate to both a recovery plan’s content and submission frequency. Banks will be informed on the specific parts of a recovery plan that they may submit in simplified form. Also, the plan’s submission frequency is the same as that of our SREP decisions. A bank must submit its recovery plan to us by 31 December of the year in which it received the SREP decision.

DNB assesses the recovery plan within six months. In case the plan is of insufficient quality, the bank must improve and resubmit it within two months, in accordance with Section 23g(3) of the Decree on Prudential Rules for Financial Undertakings ( Besluit prudentiële regels Wft ).

Disclaimer

This DNB policy statement differs from our regular policy statements as described in the Explanatory guide to DNB's policy statements . This is because we wish to retain flexibility so that we can from time to time bring the exact degree of proportionality we apply in line with new rules and practices, as allowed under Commission Delegated Regulation 2019/348. DNB therefore decides each year, for every bank individually, whether it is eligible for simplified obligations and exactly what these will entail. This policy statement is intended to provide additional transparency on our approach.

Base law

Gedelegeerde Verordening 2019/348 (Refers to an external site)

Artikelen 23d-23h van het Besluit prudentiele regels Wft (Refers to an external site)

Artikelen 4-9 van de BRRD (Refers to an external site)

Discover related articles

Factsheet

Banks

Share:

Share on LinkedIn

Share on X

Share on Facebook

Share via Email

Interesting articles

Prudential rules do not hinder bank financing for EU priorities

17 July 2026

News item supervision

Europe faces historic investment challenges, in which banks will play an important financing role. Prudential requirements strengthen banks’ resilience, without posing a major obstacle to their financing. Unlocking more private finance requires better risk-sharing and deeper financial integration.

Read more Prudential rules do not hinder bank financing for EU priorities

News item supervision

17 July 2026

DNB Inhouse Day for the Dutch banking sector: financial crime supervision

16 July 2026

News item supervision

Following last year’s successful event, De Nederlandsche Bank (DNB) will again host an Inhouse Day for AML/CFT professionals in the Dutch banking sector. The event is designed to encourage dialogue and provide further insight into DNB’s AML/CFT supervision.

Read more DNB Inhouse Day for the Dutch banking sector: financial crime supervision

News item supervision

16 July 2026

Fine for ABN AMRO Bank N.V. for inadequate customer due diligence for high-risk customers

09 July 2026

Enforcement measures

De Nederlandsche Bank (DNB) imposed an administrative fine of €8.5 million on ABN AMRO Bank N.V. (ABN AMRO) on 6 July 2026 due to serious shortcomings in its anti-money laundering controls in the period from September 2023 through September 2024.

Read more Fine for ABN AMRO Bank N.V. for inadequate customer due diligence for high-risk customers

Enforcement measures

09 July 2026

De Nederlandsche Bank publishes ‘Integrity Supervision in Focus 2026’

25 June 2026

News item supervision

In the third edition of ‘Integrity Supervision in Focus’ (ISF), we share the key insights from our integrity supervision.

Read more De Nederlandsche Bank publishes ‘Integrity Supervision in Focus 2026’

News item supervision

25 June 2026

Necessary cookies

To ensure the proper operation of the website, De Nederlandsche Bank (DNB) uses functional cookies and analytics cookies, and has taken measures to ensure that these cookies have little or no impact on the privacy of website users.

Optional cookies

Some pages include embedded content from external websites. These websites may use proprietary (tracking) cookies. This allows third parties to track visitor statistics, show personalised content and display targeted ads, for example.

You can make your choice about allowing these optional cookies both when you first visit the website and when you navigate to a page with embedded content.