Initial screening for second-tier senior officers

Factsheet

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Bank and insurance managers reporting directly to the management board and responsible for activities with a potentially material impact on the institution’s risk profile are also screened for suitability and integrity.

Published: 11 November 2022

To apply for an integrity screening please use the digital form via Supervisory applications on My DNB. This form should also be used when a change of role within the same institution is applied for a person that is in scope of the target group of second-tier senior officers.

This group of ‘second-tier senior officers’ are individuals that meet the following criteria:

They work for a bank or insurer incorporated in the Netherlands.

They hold management positions just below the first tier of directors.

They are responsible for individuals whose activities can materially affect the institution’s risk profile.

This target group will differ per institution and will not always include all managers reporting directly to the management board. Prudential risks inform the actual demarcation of the target group, i.e. risks that – should they materialise – immediately impact the institution’s financial solidity.

The target group includes at least the following persons:

superiors of the individuals authorised to enter into financial obligations in the financial markets on behalf and for the account of the institution, e.g., the head (the most senior manager) of an asset management or treasury department;

managers that bear ultimate responsibility for recruitment policies for risk-sensitive positions in the target group;

managers in the compliance, risk and audit functions;

managers of the actuarial function;

managers at insurers, at least those managing Solvency II key positions ;

managers that bear ultimate responsibility for legal affairs;

managers authorised to decide on risk mitigation measures to prevent fraud;

managers in a position to decide the magnitude of the risks traders within the institution are allowed to take when investing.

This target group of second-tier senior officers does not necessarily coincide exactly with the senior managers classified as identified staff under the Regulation on Sound Remuneration Policies (RBB Wft 2014 by its Dutch acronym), as these regulations serve different purposes.

Examples of managerial positions that are not included are: managers responsible for strategy, tax, reporting, operations, IT, property, products, client services, front office, marketing, sales, commercial departments, recovery, organisational change/transformation office, project management office, communications, innovation, sustainable development/sustainability, procurement office, facility services, directors’ office.

Disclaimer

This DNB policy statement is currently under review in light of Directive (EU) 2024/1619 (Capital Requirements Directive; CRD6), which is expected to enter into force for credit institutions in mid-2026. This policy statement will be amended accordingly. With the introduction of the new Article 91a CRD6, the concept of the second tier senior officers for credit institutions will be replaced by the term “key function holder.” Until the revision is finalized, this policy statement remains applicable.

Find out more? Go to information about:

Second-tier senior officers: integrity screening

Second-tier senior officers: suitability requirements

Second-tier senior officers – FAQs

Fit and proper assessments

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