Regulatory Alerts2016-03-04
Added · Updated
Second-tier senior officers: suitability requirements
Banks and insurers must determine whether their second-tier senior officers are suited to their positions by assessing sufficient knowledge, skills, and professional behavior. Institutions are required to draft a suitability assessment for all screened managers, which should not exceed one page and must demonstrate alignment with the job profile and the institution's situation. While the assessment does not need to be submitted to the DNB, the regulator may review the institution's process setup or perform sample tests and, in some cases, conduct its own suitability screening. This policy statement remains applicable until the introduction of Article 91a of CRD6 replaces the concept with 'key function holder' in mid-2026.
Factsheet
Read aloud
Banks and insurers themselves decide whether the managers among their second-tier senior officers are suited to their positions. Suitability implies that these managers display sufficient knowledge, skills and professional behaviour to properly perform their duties. Institutions are expected to draft a suitability assessment for all managers they screen.
Published: 04 March 2016
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.
Suitability assessment
Second-tier senior officers are assessed on the basis of their job profiles, and it should take no more than one sheet of paper to describe why they are suitable for their position. The assessment should demonstrate that they have the knowledge, experience and competences described in the profile, as well as that they fit in with the institution’s situation. The suitability assessment does not need to be sent to DNB.
Screening by DNB
We may check the process set-up at the institution as well as perform sample tests to check the quality of its assessment. In some cases we may decide to perform our own suitability screening.
Find out more? Go to information about:
Initial screening for second-tier senior officers
Second-tier senior officers: integrity screening
Second-tier senior officers: suitability requirements
Second-tier senior officers – FAQs
Fit and proper assessments
Discover related articles
Factsheet
Assessments
Banks
Insurers
Share:
Share on LinkedIn
Share on X
Share on Facebook
Share via Email
Interesting articles
Prudential rules do not hinder bank financing for EU priorities
17 July 2026
News item supervision
Europe faces historic investment challenges, in which banks will play an important financing role. Prudential requirements strengthen banks’ resilience, without posing a major obstacle to their financing. Unlocking more private finance requires better risk-sharing and deeper financial integration.
Read more Prudential rules do not hinder bank financing for EU priorities
News item supervision
17 July 2026
DNB Inhouse Day for the Dutch banking sector: financial crime supervision
16 July 2026
News item supervision
Following last year’s successful event, De Nederlandsche Bank (DNB) will again host an Inhouse Day for AML/CFT professionals in the Dutch banking sector. The event is designed to encourage dialogue and provide further insight into DNB’s AML/CFT supervision.
Read more DNB Inhouse Day for the Dutch banking sector: financial crime supervision
News item supervision
16 July 2026
Dutch insurers and pension funds have been investing more in private assets in recent years
15 July 2026
News item supervision
Dutch insurers and pension funds are investing more and more in private assets, such as private equity and private credit. By 2025, they had a combined total of €276 billion worth of these investments on their books.
Read more Dutch insurers and pension funds have been investing more in private assets in recent years
News item supervision
15 July 2026
Fine for ABN AMRO Bank N.V. for inadequate customer due diligence for high-risk customers
09 July 2026
Enforcement measures
De Nederlandsche Bank (DNB) imposed an administrative fine of €8.5 million on ABN AMRO Bank N.V. (ABN AMRO) on 6 July 2026 due to serious shortcomings in its anti-money laundering controls in the period from September 2023 through September 2024.
Read more Fine for ABN AMRO Bank N.V. for inadequate customer due diligence for high-risk customers
Enforcement measures
09 July 2026
Necessary cookies
To ensure the proper operation of the website, De Nederlandsche Bank (DNB) uses functional cookies and analytics cookies, and has taken measures to ensure that these cookies have little or no impact on the privacy of website users.
Optional cookies
Some pages include embedded content from external websites. These websites may use proprietary (tracking) cookies. This allows third parties to track visitor statistics, show personalised content and display targeted ads, for example.
You can make your choice about allowing these optional cookies both when you first visit the website and when you navigate to a page with embedded content.