Regulatory Alerts2024-01-25
Added · Updated
Results of Consultation on Q&A Regarding Supervisory Boards at Payment and Electronic Money Institutions
The Dutch Central Bank (DNB) published the results of a consultation on its proposed Q&A concerning supervisory boards for payment institutions and electronic money institutions, receiving feedback from the Electronic Money Association and the Association of Dutch Payment Institutions. DNB confirmed that it applies the principle of proportionality when assessing whether smaller institutions can maintain a supervisory board, noting that size is a key criterion and alternative solutions may be appropriate. The regulator also clarified that there are no statutory restrictions on appointing non-Dutch-resident supervisory directors, provided they pass fit and proper assessments and can commit sufficient time to their duties. Finally, DNB maintained that the Q&A does not constitute gold-plating, as it merely interprets existing legal frameworks rather than introducing new supervisory standards.