AFM Annual Report 2025

AFM AI ACCOUNTABILITY ANNUAL REPORT Annual Report 2025 In brief In 2025, the AFM worked towards fair, transparent, and future-proof financial markets. We strengthened the protection of consumers and investors, improved sustainability information, and prepared the sector for new European rules, such as DORA, MiCAR, and the CSRD. We also took action against fraud, misleading practices, and illegal services. Through data-driven supervision, sharp enforcement, and close European cooperation, we contributed to a safe, honest, and digital financial sector.

ACCOUNTABILITY ANNUAL REPORT Table of Contents

1. Supervision of financial services 6
2. Supervision of capital markets 12
3. Supervision of asset management 17
4. Supervision of accounting and reporting 20
5. Prevention of criminal behavior 23
6. Stakeholder engagement 26
7. Organization and governance 34
8. Report of the Supervisory Board 48
9. Annual accounts 53 Independent auditor's report 77 Appendix 1: KPIs 82

Key Figures 2025 AFM as gatekeeper Influence Enforcement AFM Total number of licenses 375 30 16 311 Supervisory area asset management 30 (+8) Supervisory area financial services 311 (+17) Supervisory area quality of audit and reporting 16 (+6) Total assessments 2,284 As a gatekeeper, the AFM continuously monitors compliance with laws and regulations. This often focuses on correct and transparent processes at financial companies. This exists alongside thematic supervision where we look at 'more acute' risks. From the supervision of ongoing activities, we focus, for example, on license applications, assessments of executives, and prospectus supervision. i Total number of contact moments 14,504 (1,742 vs. 2024) 3,767 10,737 Entrepreneurs' Portal 2,774 5,051 5,686 993 What are contact moments? Consumers and entrepreneurs can contact the AFM via the Financial Markets Complaints Point or via the Entrepreneurs' Portal. Both can be reached by phone and email. 18 Crypto companies 18 (+18) (49 vs. 2024) What are assessments? Persons who (co-)determine the policy of a company or supervise this policy must be reliable and/or suitable for exercising their function. They are assessed on this by the AFM and/or DNB. The assessment has various elements. 0 300 600 900 1,200 1,500 Re-assessment Double gates Audit firms Crypto asset service providers Investment objects and stock exchange Investment companies/institutions Advisers/brokers/credit providers 1,419 580 19 64 192 7 3 -10 +6 +64 +5 -1 Mutation vs. 2024 -19 Annual Report 2025 3 ACCOUNTABILITY ANNUAL REPORT

Total number of publications 80 AFM publications In reports, we outline findings from our investigations and offer improvement points. With consultations, we give our own opinion on a bill or ask the sector to respond to our policy statements. With a supervision test, we clarify what new legislation means for supervision. With a sector letter, we link our findings back to a sector. In 2025, AFM published 100 sector and press releases on AFM.nl Supervisory area financial services 46 Supervisory area capital markets 7 Supervisory area asset management 13 Supervisory area accounting and reporting 14 46 7 13 14 Reports Consultations and supervision tests Guidelines Sector letters Other xx Total AFM as gatekeeper Influence Enforcement AFM Key Figures 2025 Media articles in total 2,738 articles Activity on LinkedIn Reach 1,022,000 accounts Number of followers 54,600 accounts (+5,200) Impressions 1,900,000 times 0 50 100 150 200 Jan 1 Mar 1 May 1 Jul 1 Sep 1 Nov 1 Jan 1 Total AFM reporting in 2025 (print and online news media) • Fine Saxo Bank Fine BDO • +Investment fraud • + Margin personalization • Pump and dump • + Suspend trading NX Filtration • Investigation finfluencers • Ajax/ Alex Kroes • Financial stability • Gen Z • Market manipulation • Annual Report Most reporting came from trade media. But also titles with high reach among the general public (such as Het Financieele Dagblad, fd.nl, nu.nl and the Algemeen Dagblad) score high. • Trend view NEWSPAPER Sector and press releases Press release 100x Annual Report 2025 4 ACCOUNTABILITY ANNUAL REPORT

Total informal measures 446 (19 vs. 2024) Supervision letters / discussions Warnings boilerrooms Norm transfer warning letters Informal measures are measures that are norm-informing, such as a supervision letter, or - in the most severe case - a warning letter. Warnings for 'boilerrooms' (investment fraud) we publish on our website and on social media. AFM as gatekeeper Influence Enforcement AFM Imposed fines 8 Imposed compliance orders under penalty payment 1 Reports 2 License revocations 1 Other 11 Formal measures are measures that the law offers us, such as imposing a fine or a report. Total formal measures 23 (9 vs. 2024) The AFM has the task of supervising compliance with the financial laws and regulations. A starting point is that we take action as soon as we are aware of an violation. The way we do this then depends on the concrete situation. We can make use of formal and informal measures. i €16.7 million Amount collected from formal measures 134 119 193 Annual Report 2025 5 ACCOUNTABILITY ANNUAL REPORT

Annual Report 2025 6 ACCOUNTABILITY ANNUAL REPORT

1. Supervision of financial services For 2025, the AFM set itself a number of goals within the supervision of financial services in the Agenda 2025. • Customer interest in relation to financial innovation and technology. • Supervision of compliance with the new European crypto legislation. • Financial products recommended as sustainable do what they promise. • There is a better picture of cross-border services. • The new pension schemes fit participants because pension funds explicitly take the interest of their participants into account in their decision-making regarding the transition. • Retail supervision is based on responsible data use. Customer interest in relation to financial innovation and technology In 2025, we contributed to good and appropriate digital financial services: customer interest is sharply safeguarded for new products and algorithms, crypto information is clear, and compliance with rules is strict. What did we do for this? We investigated technological trends and IT change management in credit lending, the implementation of the Accessibility Directive and the characteristics of a new generation that grew up in a digital age: Gen Z. Within our supervision of the insurance market, we published handles for safeguarding customer interest in embedded insurance regarding the statutory license requirement, product development and information provision. Furthermore, research showed that half of the property insurers calculated higher profit margins for loyal customers; premiums were adjusted where necessary. To maintain supervision of placing customer interest at the center of algorithmic applications, we developed both supervision methodologies and an assessment framework. An algorithm must be among other things accurate, explainable, correct, and fair. We tested this based on a pilot. We shared our insights within the European insurance and occupational pensions authority (EIOPA). We further conducted explorations into where insurers, banks, advisers, credit providers, and investment service providers use artificial intelli- gence (AI) (can) use and what this means for customer interest and our supervision. This will continue in the years after 2025. In our investigations into information provision and advertising about crypto assets, we saw good practical examples, but also examples where there is still 'work to be done' for the Crypto Asset Service Providers (CASPs). For example, we saw that sometimes talk is had about safe trading in crypto, without further explanation or context. For correct, clear, and non-misleading information provision, it is important that risks are not belittled, especially given the volatility of crypto assets. We also encountered cases where on the website there was no or insufficient information about the rates and costs. After this investigation, we paid extra attention during the processing of license applications from crypto companies, whether their advertising statements and information provision were in order. We spoke to various illegal crypto service providers because they did not comply with the law to prevent criminal behavior. We also published a public warning regarding a large-scale illegally operating crypto platform. We checked during license applications to what extent crypto companies comply with the Act on the Prevention of Money Laundering and Financing of Terrorism (Wwft), the Transfer of Funds Regulation (TFR) and the Sanctions Act and how they prevent market abuse. In 2025, the registration regime at De Nederlandsche Bank (DNB) ended and we started with the supervision of crypto service providers.

Annual Report 2025 7 ACCOUNTABILITY ANNUAL REPORT In new research into buy now, pay later (BNPL) we looked at payment difficulties and arrears. We also investigated the financial health of BNPL users between 18 and 34 years. It appeared that a part of this group is possibly financially vulnerable. In our supervision of crowdfunding service providers, we published a step-by-step plan for market parties, addressed companies on their bulletin board services, and clarified norms. Furthermore, we updated our information for consumers. Within our own organization, we work increasingly data-driven with data clusters and DevOps teams. An example is delivering a dashboard with data on the life insurance market, such as the size of portfolios and the development of complaint figures. This dashboard makes it possible to make data-driven choices to make and substantiate. What is the impact? Our findings regarding Gen Z and technology in cre- dit lending we shared with society and the sector. We launched a Q&A and complaint point to help the sector with the Accessibility Directive. Thereby we increased the awareness in the sector about the risks of digitalization and stimulated the so- cial dialogue. After talks with insurers about margin personalization, both premiums and premium policy were adjusted where necessary. By, just like in 2024, paying attention to advertising and information from crypto service providers, we see that marketing and information provision from crypto companies more often meets the new requirements. Our efforts against non-honest or non-compliant behavior by crypto companies led to measures such as letting customers expire, applying for a license, adjusting the service or adjusting advertising statements. Crypto companies implemented many improvements so that they can better act as a gatekeeper in the field of money laundering and terrorism financing. Various providers of buy now, pay later sharpened their communication, payment reminders, and risk management. Furthermore, the cabinet presented a bill that introduces mandatory age verification for the use of buy now, pay later services. This follows our call to do something about circumventing age controls for BNPL by minors. As a result, vulnerable young people will be better protected in the future. Sustainability We ensured that sustainable financial products better align with what they promise, so that consumers with sustainable goals are treated fairly and appropriately. What did we do for this? We saw risks of non-appropriate sales (mis-selling) of finan- cial products to consumers with sustainable goals. For example, because sustainability claims of financial under- takings did not meet the required quality level. Or there is insufficient attention at investment companies for sustain- ability in the distribution of their products and services. We looked at the sustainability claims of various banks, investment companies, insurers, and pension providers. Especially the concreteness of claims and the findability of the substantiation needed improvement. We shared our findings with the involved undertakings. In a European context, we checked compliance with sustainability requirements regarding pro- duct oversight and governance (POG) and the suitability test at six investment companies. From this research we concluded that it can and must be better. We addressed companies on this.

Annual Report 2025 8 ACCOUNTABILITY ANNUAL REPORT A planned investigation into the compliance of the Sustainable Finance Disclosure Regulation (SFDR) by asset managers and life insurers we postponed, because the European Commission wants to revise this legislation and we first want clarity on this. The investigation into how property insurers substantiate sustainability claims was published in early 2026. What is the impact? As a result of our interventions, all companies where we had findings adjusted their sustainability claims immediately or stated that they wanted to implement improvements. Investment companies agreed to improve their POG and suitability tests. Thereby we increase the chance that sustainable products do what they promise and that consumers get access to products that align with their sustainability goals. Cross-border services In 2025, we ensured that consumers are better protected against cross-border risks and new forms of financial services, through sharp supervision and European cooperation. What did we do for this? Because the insurance market is increasingly cross-border, we included more foreign insurers in our annual complaint survey. Furthermore, we investigated the remuneration of power of attorney agents in death risk insurance, also by foreign providers. Finally, foreign insurers were part of the thematic review of EIOPA into the treatment of customers with certain chronic diseases. This has two goals. We want to protect the consumer in the Netherlands in an international market AND we want to strive for a level playing field within Europe. At several neo-brokers, we saw risks for investors in investigations, such as hidden or unnecessary costs and non-appropriate products. We warned the involved neo-brokers. In some cases, the investigation is not yet completed and follows up in 2026. Furthermore, we saw potential problems in the management of payment arrears. We therefore conducted research into the arrear management at credit providers. What is the impact? Neo-brokers have improved their services. For example, the cost information is more transparent, target groups have been sharpened, and suitability tests have been improved. And as a result of our research into the management of payment arrears, credit providers agreed to improvements to help customers with payment problems better. New pension system The pension sector informs participants increasingly better about what they can expect in the transition to the new second pillar pension system What did we do for this? We advocated for preventing unrealistic expectations and foreseeable disappointments. This plea initially found no echo everywhere, but the sector has taken steps in 2025. We looked in 2025 at information provision about survivor pension, the importance of a personal explanation for scenario amounts, and compensation for the abolition of the average system. We asked for action from the last 10% of the pension providers who did not yet have a correction policy. Furthermore, we assessed 80 communication plans and scrutinized transit communication of pension funds, insurers, and premium pension institutions (PPIs). Thereby we also looked at whether the way pension providers inform their participants works. Based on this research, we gave five recommendations, such as checking an email address. We maintain risk-based supervision

Annual Report 2025 9 ACCOUNTABILITY ANNUAL REPORT and prioritize ongoing. In 2025, we therefore postponed the planned investigations into order confirmation and risk preference. We shared our research findings and practical examples via our website, publications, media, and the Transition Bulletin. We also went to talk with pension providers and industry associations, for example via office visits and phone rounds, and via introduction with new executives. Furthermore, we organized roundtable discussions on choice guidance, a webinar on order confirmation, made podcasts on open norms and compensation, held our annual Pension event, and participated in the AFM/ DNB Transition Platform. This allowed us to effectively convey our mes- sages and timely collect issues and dilemmas for which further guidance is needed. What is the impact? The sector stated that it would use the recommendations on the method of communicating with participants in its communication. The report on the new norm 'choice guidance' led to pension providers taking the shared insights into account in their further development of choice guidance. Thereby we realized that pension providers can better support their participants in making appropriate choices. Advisers and brokers The sector and we have worked hard to improve the quality of mortgage advice and strengthen a controlled and honest business operation at advisers. What did we do for this? After the exploration 'Quality of mortgage advice' (October 2024), we conducted talks with various stakeholders, such as advisers, trainers, industry organizations, and software providers on how to improve the quality of mortgage advice and whether updating the old guideline could contribute to this. It appeared that advisers and trainers still use the existing guideline frequently, and that the guideline in the basis still aligns with the prevailing norms and the current practice. Stakeholders stated that they would like to see that the guideline more concretely describes how advisers in practice can give substance to existing norms. Furthermore, it appeared that there was a need for clearness on new topics such as sustainability and relationship termination. We periodically monitor whether advisers, brokers, and power of attorney agents meet a number of basic norms that contribute to a strong business operation. This fits into the multi-year program with which we lay a solid foundation for a level playing field within which a sustainable and compliant business operation is the norm. In 2025, we sent 868 norm-informing letters in this context. We pointed parties hereby explicitly to their legal duties and thus explicitly aimed at compliant behavior. We also urged them to improve on specific points and pointed out their own responsibility in this. A norm-informing letter is not a measure and does not lead to a supervision antecedent. The safeguarding of customer interest also had great attention from us. Together with parties, we mapped their maturity on topics such as tone at the top, compliance, and culture. Office visits gained more space in supervision. In 2025, almost 50 conversation sessions were held with financial service providers throughout the country. The topics of conversation varied. For example, in 2025, a number of conversations also focused on collective license holders and the question of whether they have demonstrable insight and grip on their affiliated companies. We also visited some advisers to whom we recently granted a license and spoke about complying with the rules and the licensing process. At the end of 2025, we offered a renewed guideline for mortgage advice for consultation to the market. What is the impact? The office visits and talks with advisers contribute to a controlled and honest business operation and improved approach to market access.

Annual Report 2025 10 ACCOUNTABILITY ANNUAL REPORT Ongoing supervision activities In our investigation into third-pillar pension products, we saw risks of unrealistic expectations, which could cause consumers to come into financial trouble from their retirement age. We addressed providers of pension products and asked for improvement plans. Furthermore, we noticed that a number of small investment companies did not sufficiently safeguard that portfolios align with the financial position and risk appetite of customers. We gave a warning to the involved investment companies or imposed a directive. All companies proceeded to improve their pro- cesses and remedy the shortcomings. Thereby, the chance is reduced that their customers come into financial trouble. We also concluded that advertising statements of a company did not meet the regulations, so that customers were insufficiently informed about the risks. We fined this company. In 2025, we granted 311 new licenses to financial service providers. This concerns both extensions to a collective license, changes in legal form, as well as completely new licenses. We investigated riskier applications more deeply than less risky applications. 34 applications ultimately did not lead to license issuance. Also, in the notification of affiliated companies by a collective license holder, we looked critically at requirements. In 11 cases, this did not lead to a completed notification as a result of substantive questions, in 218 cases we completed the notification. In total, 552 financial service providers asked us to revoke their license. Some of these companies stopped their activities for which a license is needed. Others continued in a different way, for example as an affiliated company at another license holder or they merged or were acquired, whereby the activities continue under another license. In 2025, we had 36 license applications and notifications for crypto service providers in processing. Some applications were not good enough and we could not (further) process them after our feedback. Many parties submitted a new (improved) application, but not all parties succeeded in this. Ultimately, we granted 15 MiCAR licenses in the reporting year. Furthermore, 3 notifications were successfully processed. At this moment, there are still various license applications and notifications in processing. In ongoing supervision, we see that crypto service providers are busy with implementing the recently established policy and proce- dures and that there are relatively many changes compared to other sectors on both organizational and commercial levels. In 2025, we focused our supervision