Management committee report on the effectiveness of organisational measures and statement on periodic prudential reporting

NBB_2025_18 – 25 November 2025 Circular – Page 1/12 14 Boulevard de Berlaimont – 1000 Brussels +32 2 221 38 12 Company number: 0203.201.340 Brussels RLE www.nbb.be Circular Brussels, 25 November 2025 Reference: NBB_2025_18 Your contact:
Nicolas Strypstein
Tel. +32 2 221 44 74 – Mobile +32 494 53 38 90 nicolas.strypstein@nbb.be Management committee report on the effectiveness of organisational measures (including those applicable specifically to investment services and activities) and statement on periodic prudential reporting Scope1 Credit institutions, stockbroking firms, payment institutions, electronic money institutions, institutions providing support to central securities depositories, approved or designated financial holding companies and mixed financial holding companies and investment holding companies incorporated under Belgian law, as well as Belgian branches of the aforementioned institutions when the latter are incorporated under the law of a non-EEA country and Belgian branches of aforementioned institutions where the latter are incorporated under the law of an EEA country (restriction to provisions of general interest). Summary/Objectives This circular updates and replaces Circular NBB_2011_09 dated 20 December 2011 on (i) the assessment report by the senior management on the system of internal control, (ii) the assessment report by the senior management on internal controls in relation to investment services and activities and (iii) the statement by the senior management on periodic prudential reporting. Having regard to intervening changes2 in the prudential supervisory legislation and in order to reduce the administrative burden associated with preparing the reports mentioned in points (i) and (ii) above, these reports are replaced by a single “management committee report on the effectiveness of organisational measures”. The main changes compared to the former reports on internal control are:
i. revision of the scope ratione materiae;
ii. integration of the descriptive section of the former report on the system of internal control into the
governance memorandum so that the new report focuses solely on the effectiveness of organisational measures and the measures taken to remedy any shortcomings identified;
iii. integration of the report on specific organisational measures in relation to investment services and
activities into the general report on organisational measures; and
iv. alignment of the reporting framework with that of the governance memorandum.
1 Specific areas of application are specified in the body of the circular; these are more precise and take precedence. 2 Circular NBB_2011_09 was based on the former Banking Act of 22 March 1993, which referred to the report by senior management on internal control. This wording was revised in 2014, when the new Banking Act of 25 April 2014 was published, to refer to the “management committee report on the effectiveness of organisational measures”.