2017-07-19
Added · Updated
Insurers with registered offices in the Netherlands must obtain a declaration of no-objection from DNB before reducing own funds through capital repayment, reserve distribution, or dividends if doing so would cause a breach of the solvency capital requirement or is expected to do so within twelve months. Additionally, insurers must secure DNB approval to change their capital structure by submitting shares or other controlled securities for admission to trading on a regulated market. This DNO obligation for initial public offerings applies with effect from 1 January 2025. DNB assesses these applications based on solvency, sound business conduct, and potential undesirable developments in the financial sector.
Factsheet
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Insurers having their registered office in the Netherlands need prior approval from DNB for two acts mentioned in the Financial Supervision Act (Wet op het financieel toezicht – Wft). They can obtain this approval by applying for a declaration of no-objection (DNO).
Published: 19 July 2017
Latest update: 12 March 2025
Reducing own funds – Section 3:97(a) of the Wft
Insurers need a DNO to reduce their own funds by paying back capital or distributing reserves, or by making dividend distributions. The DNO obligation applies only if the insurer at the moment of making these payments or distributions does not comply with the solvency capital requirement, or if it is expected to not (or no longer) be able to meet this requirement in the next twelve months.
Initial public offering – Section 3:97(b) of the Wft
Insurers need a DNO to change their capital structure by submitting a request for admission to trading on a regulated market of shares or other securities to which control is attached.
The DNO obligation for IPOs applies with effect from 1 January 2025, making it the most recent amendment to Section 3:97 of the Wft.
DNB’s assessment criteria
DNB assesses an insurer's DNO application using the criteria set out in Section 3:101 of the Wft. These criteria deal with solvency, sound and prudent conduct of business operations and whether the act might or would lead to an undesirable development of the financial sector.
Information Declaration of no-objection
Declaration of no-objection
Definition of qualifying holding
Qualifying holding
Bandwidth DNO
Declarations of no-objection (DNOs) for group companies
Umbrella DNO
Different types of DNO
DNO for shareholdings (Section 3:95 of the Wft)
DNO for acts of banks (Section 3:96 of the Wft)
DNO for acts of insurance companies (Section 3:97 of the Wft)
DNO for MiCAR (Articles 41 and 83 MiCAR)
Applying for a DNO
DNO application form and explanatory notes
DNO application procedure (10 steps)
DNO application time frame
DNO application fees
DNO application - success factors
General information
DNO requirements and restrictions
Publication in the Government Gazette
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