Financial Stability Committee Report 12 November 2025

In the Financial Stability Committee (FSC), representatives from the Authority for the Financial Markets (AFM), De Nederlandsche Bank (DNB), and the Ministry of Finance discuss developments regarding financial stability in the Netherlands. The Central Planning Bureau (CPB) participates in the meetings as an external expert. The President of DNB serves as the chair of the FSC.

During the meeting on 12 November 2025, three main topics were discussed: current risks to financial stability, operational and digital resilience, and the recommendation of the European Systemic Risk Board (ESRB) regarding multi-issuer stablecoins.

Current Developments and Risks to Financial Stability

The Dutch economy presents an overall stable and resilient picture, despite geopolitical tensions and uncertainties in the international environment.1 Growth and inflation in the Netherlands are slightly above the euro area average. Looking ahead, inflation is expected to move more towards the European average, primarily due to moderating wage developments. The Dutch labor market remains tight, albeit to a lesser extent than in recent years, with currently more job seekers than vacancies. The impact of trade levies on the economy has so far been manageable, partly because the effective levies in many cases turned out to be lower than initially announced. However, the FSC expects that the effects of the levies are only partially yet to materialize.

The FSC notes that heightened geopolitical and international tensions remain the primary risk to Dutch financial stability.2 It is notable that financial markets are currently presenting a picture of calm, while underlying risks are increasing. For example, valuations have risen further, with concentration risks on stock markets and significant price increases for companies investing in technology and artificial intelligence. This increases the likelihood of a potential correction. This is particularly relevant for Dutch pension funds, where a significant portion will transition to the new pension contract at the beginning of next year. In general, it is important to monitor the consequences of this transition for the investment policy of pension funds, particularly with regard to interest rate derivatives.

The starting position of Dutch public finances is sound, but the budget deficit is rising again in the short term, bringing it close to the limits agreed upon in the European budgetary rules. The FSC also sees increasing risks regarding government debt sustainability outside the Netherlands. On financial markets, however, this has not yet translated into significant stress. Member states are responsible for bringing their budgetary positions into order, also due to the need to accommodate additional expenditures related to defense and aging.

Dutch financial institutions possess strong buffers and are well-positioned to absorb shocks. At the same time, structural vulnerabilities and the increasing interconnection between banks and non-bank entities remain a source of concern. It is important for financial institutions to think through and practice stress scenarios. The FSC also notes that further steps are being taken to simplify the supervisory framework. Given the increased stability risks, it is important that the resilience of the financial system remains at least at its current level during this simplification.

Operational and Digital Resilience

The FSC discusses progress in strengthening the operational resilience of the financial system. Due to extensive digitalization, geopolitical tensions, and increasing dependence on third parties, the importance of operational resilience has increased. The FSC notes that operational risks are also high on the agenda of financial institutions. Within the Netherlands, supervisors, the government, and the financial sector are collaborating on, among other things, the continuity of payment flows and cyber resilience.

There is broad appreciation within the FSC for the work already carried out by all parties to enhance operational resilience. The Dutch approach is also positively valued internationally, particularly with regard to cyber resilience.3 At the same time, the FSC emphasizes that the work is never finished and requires continuous attention to reduce vulnerabilities. It is important to look broader than just the financial sector, given the dependencies with other sectors, such as energy and telecommunications.

The FSC also notes increasing digital dependencies.4 Financial institutions are increasingly dependent on a limited, often non-European group of cloud providers and suppliers of specific IT services for the execution of critical processes. This has created concentration and systemic risks. In the short term, this issue is not easy to resolve, partly because alternatives are limited. European initiatives and diversification are necessary to reduce digital dependence, thereby increasing strategic autonomy. The DORA regulation, introduced earlier this year, also provides a framework for supervising critical third parties. The FSC emphasizes that it is desirable to assess whether the existing regulatory framework inadvertently favors large third parties.

The FSC supports the importance of continued attention to operational and digital resilience and has agreed to discuss in a subsequent meeting what is needed at the European level to increase strategic autonomy in this area.

ESRB Recommendation Regarding Stablecoins

The FSC discussed the recent recommendation of the ESRB regarding stablecoins issued in multiple jurisdictions.5 These so-called multi-issuer stablecoins bring risks due to uncertainty regarding claims on reserves and differences in regulation. The ESRB advises against allowing such structures unless measures such as equivalence requirements are introduced to mitigate the risks.

FSC members recognize that stablecoins can add value in cross-border transactions, but that significant risks are associated with them. It is important to strike a balance between managing risks and maintaining space for innovation. The FSC has agreed to discuss stablecoins again at a later stage.

The next FSC meeting will take place on 20 March 2026. Members may submit suggestions for the agenda in advance.

1 Estimate September 2025 (MEV 2026) | CPB Website 2 Overview of Financial Stability - Autumn 2025 | De Nederlandsche Bank, Trend Outlook 2026 3 Peer Review of the Netherlands - Financial Stability Board 4 AFM and DNB warn of systemic risks in the financial sector due to digital dependence | De Nederlandsche Bank 5 Recommendation of the European Systemic Risk Board of 25 September 2025 on third-country multi-issuer stablecoin schemes (ESRB/2025/9)