Sector in Focus: Financial Service Providers

ANALYSIS SECTOR IN FOCUS
Financial health
Outsourcing
Affiliated companies
Sector
Customers
Providers
Staff
Financial service providers
Trust in the financial services sector
In brief The theme of this publication is trust in the financial services sector and who holds which responsibility in this regard. Giving trust and taking responsibility is a joint mission that is reciprocal. Both the supervisor, as well as the provider and advisor: everyone has their own role in strengthening trust in the sector. The ultimate result of this joint mission is increasing the financial health of households in the Netherlands. NOVEMBER 2025

ANALYSIS SECTOR IN FOCUS
Table of Contents

1. Introduction and reading guide 3
2. Summary and Foreword by Head of Supervision 4
3. Theme 2025: Trust and Responsibility 6
4. Market Data 9
5. Results of Investigations 16
   5.1 Collective license holders: be truly in control! 16
   5.2 Preventing mortgage fraud requires alertness 18
   5.3 IT services and the risks thereof 20
   5.4 Office Visits 2025 21
   5.5 Securing customer interest: valuable insights 23
6. Current Affairs and Points of Attention 25
   6.1 Accessibility Directive from 28 June 2025 25
   6.2 Update of the investigation into mortgage advice quality 26
   6.3 Reporting incidents and registering complaints 27
   6.4 Pension advisor and executor: work together for a timely pension transition for the customer 28

Trust in the financial services sector
ANALYSIS SECTOR IN FOCUS

1. Introduction and reading guide
   For the sixth consecutive time, the AFM publishes 'Sector in Focus Financial Service Providers' (formerly Market Impressions). In this publication, the AFM provides insight into the sector of financial service providers (advisors, intermediaries, and authorized agents, hereinafter 'fd'ers'). The input for this publication comes from the questionnaire for the Market Monitor Advisors and Intermediaries (MMAB) which fd'ers filled out in the spring of 2025 regarding 2024. With the information from this annual request, the AFM gains better insight into the market, developments, and risks. This allows us to deploy our supervision more targeted and help improve the quality of financial services and increase trust in this market. We also incorporate information the AFM has received from conversations that take place annually with fd'ers. In addition to these regular conversations, we have also held conversations with fd'ers as part of several explorations. Finally, we share the results and recommendations of various investigations carried out in 2025 within the sector of fd'ers. The structure of 'Sector in Focus Financial Service Providers' is as follows. Chapter 2 contains the summary and a foreword by Head of Supervision Eva-Lotte Bakker. In Chapter 3, we discuss this year's theme: trust and responsibility. Key figures from the license register and outcomes from the MMAB 2025 (with data on 2024) are covered in Chapter 4. In Chapter 5, you will read the outcomes of recent supervisory investigations. In Chapter 6, we ask for your attention for current matters and provide points of attention. The information in this publication is presented in a generalized manner and cannot be traced back to individual offices.

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2. Summary and Foreword by Head of Supervision
The AFM pays attention in this publication to trust in fd'ers and the sector. fd'ers bear significant responsibility for the trust consumers have in the sector, and that trust does not come automatically. At the same time, every party in the chain, from supervisor to distributor, plays its own role in strengthening that trust. Trust and responsibility also feature in the explorations and investigations the AFM has conducted and in the contacts with market parties. Mortgage fraud remains an ongoing risk to the integrity of the financial market. Preventing it is the responsibility of many parties. The AFM will continue to focus on effectively addressing future reports concerning mortgage fraud and maintaining contacts with chain partners. Think here of the police and the Bureau Financial Supervision. Supervisory attention continues to focus on meeting license requirements. Investigations into sound and honest business operations show that not all companies meet these requirements. The AFM will also pay attention to this in 2026, after all, everyone must meet the same requirements. Collective license holders must have extra eyes and ears to ensure that affiliated companies (continue to) comply with laws and regulations. The main findings and recommendations from an exploration the AFM conducted in 2025 are shared with the sector. In 2025, competency requirements and recruiting staff were subjects frequently discussed in contacts with the sector. Finding and retaining staff for the company remains a challenge.

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Foreword by Head of Supervision Eva-Lotte Bakker:
'Investing in tomorrow's trust'
The financial services sector is at a turning point. Technology is developing at lightning speed, societal expectations are rising, and the role of financial service providers is changing accordingly. This requires investing in trust, in the sector, and in ourselves as supervisors. Artificial intelligence is a good example. AI is no longer a future vision, but reality. It promises speed, efficiency, and personalization, but it also raises questions. Who controls the algorithm? Who checks the result? And who bears the responsibility if things go wrong? As a supervisor, we want to provide space for innovation, but not without preconditions. Because trust in technology begins with transparency about its use and functioning. Thus, this foreword is a result of my personal observations in the sector over the past period, my own writing skills, and the use of AI (Copilot). At the same time, attention to financial health is growing. Not only among policymakers, but also among consumers. For the AFM, it is part of its mission: sustainable financial well-being. Financial service providers can really make a difference here. By looking broader and positively influencing behavior, advising understandable products, and taking customer interest not as a closing item but as a starting point. That requires more than compliance; it requires engagement. And then there is the third pillar: contact. Contact with the market is essential to keep supervision relevant and effective and increases mutual trust. Moreover, remote supervision is not sufficient in a sector that operates close to people. Therefore, we are intensifying our dialogue with the market, not to please, but to understand. Because good supervision begins with good listening. Only then can we assess risks sharply and act proportionally. The sector is moving, and we are moving with it. Not by letting go of everything, but by choosing more sharply. Technology, responsibility, and dialogue are not separate themes: together they form the foundation for a sector that must permanently earn tomorrow's trust. With this publication, we give you our images and expectations. We invite you to use it as a compass; for reflection, for dialogue, and for action. Because whoever invests today helps build a future-proof fd-sector.

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3. Theme 2025: Trust and Responsibility
Legend
Mutual trust, based on taking responsibility.
The stakeholders:
Financial health
Outsourcing
Affiliated companies
Sector
Customers
Providers
Financial service providers
Financial
Consumer
Other
Supervision
Financial health
Outsourcing
Affiliated companies
Sector
Customers
Providers
Financial service providers
A joint mission
Trust in the sector of fd'ers — what are we actually talking about? And more importantly: how can we strengthen that trust? This is an issue that has been a topic of conversation for some time. Responsibility plays a key role here. Because trust grows when people and organizations take their responsibility. The question is not only how we increase trust, but also how we handle it, as trust is partly based on parties taking their own responsibility. Trust is not an abstract concept; it lives within an organization, among employees, with customers, in the chain of which we are part, and in the supervision of the sector. Precisely in that interaction — taking responsibility and receiving trust — lies the strength of healthy financial services. We can approach this theme from different angles. Trust and Supervision Trust in the sector is essential for the AFM as a supervisor. At the same time, the financial sector must also be able to trust the role and actions of the AFM. The AFM works together with the fd-sector on sustainable financial well-being in the Netherlands. We do this also through our participation in the 'National Coalition for Financial Health', recently the Foundation Financial Healthy Netherlands. All participants within this coalition want to contribute to the financial health of households in the Netherlands. The AFM also counts on the fd-sector to contribute to the financial health of its customers through its own activities. fd'ers come in all shapes and sizes. Together with the sector, our goal is that consumers are helped correctly in choosing financial products and services. The sector must be able to count on the AFM, and the AFM must take its responsibility in this. This must manifest in the sector's trust in the supervision we exercise. In February 2025, the AFM published the outcomes of our stakeholder research. The research was conducted in 2024 among companies supervised by the AFM. This research shows that the sector recognizes the points of attention the AFM focuses on. However, there is criticism of the manner in which the AFM does this: too legalistic and theoretical, with insufficient consideration for practice. From earlier stakeholder research, it was already evident that the sector expects a minimum of certain activities from the AFM's supervision. Think here of contributing to a level playing field within the sector, where everyone must adhere to the same rules, and addressing undesirable behavior by market parties. The AFM has taken these points into account in its supervision and the way we organize supervision. This means that much attention remains on sound and honest business operations and that all parties continuously meet license requirements. We also want to align our activities more with the needs within this sector through contact with the sector. Through investigations and explorations and by talking to fd'ers during office visits, we see as supervisors where things are going well and where there are
still points of attention. Through these visits, we also see how it works in practice. Trust and Colleague Financial Service Provider fd'ers must also be able to trust colleague fd'ers. The AFM has previously emphasized cooperation within the sector and making choices about the target group you want to serve.1 Which product group does an fd'er focus on? Or in what way does he want to communicate with the target group? If an fd'er makes choices and thereby can no longer help his customers with all questions about financial products or services, it is important that he can tell them where they can go. To which colleague can he entrust the customer? Trust and the Chain Trust must exist in the parties you work with, such as providers of financial products (think here of banks and insurers), but also in cooperation regarding the outsourcing of tasks. It is good to realize where responsibilities lie in that cooperation. Tasks performed by others on behalf of the fd'er (outsourcing) take place under the responsibility of the fd'er. He must therefore regularly check if all agreed arrangements are still being met. The outsourced tasks remain under the fd'er's risk. 1 See our publications Cooperation of financial service providers increasingly important; record arrangements well and Making choices remains essential in the market of financial service providers 2 See also 'four pillars of a future-proof fd-sector' From an earlier investigation (see also Market Impressions 2023), it appears that control over outsourcing of tasks often leaves much to be desired and arrangements are not documented. The AFM specifically conducted research in 2025 on the outsourcing of ICT services by fd'ers. By outsourcing parts of ICT (such as processes, systems, and/or functions), companies can focus on core activities. However, risks can arise in cooperation here as well. It is important to have continuous attention for this and to take responsibility here too. A special cooperation in the chain remains the principal and authorized agent. An fd'er receives authority (power of attorney) from one or more insurers to act on their behalf. It frequently happens that foreign principals are used here. As a result, authorized agents provide Dutch consumers with financial products from foreign providers (cross-border market), making risks that are not or less easily insurable sometimes still insurable. Parties are jointly responsible for meeting all legislation that applies here as well. Trust in Own Company and Employees Last year, we paid attention in 'Sector in Focus' to 'having the house in order'. By this, we mean that it is important for a company to be in control of its operations and act in the customer's interest. You have control over your company if you are future-proof: you place customer interest at the center, you keep an eye on future developments and trends, you have a sustainable business model, and you take responsibility for sound and honest business operations.2
Once the 'house is in order', this means fd'ers can pay attention to what they like to do most: helping customers with their financial issues.

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Trust in one's own company also means that an fd'er thinks about how he leads the company and where he wants to stand in a few years. In other words, how does he ensure his company is future-proof? In many cases, an fd'er does not do this alone. He builds the future together with his employees. Responsibility and trust come together here. Is there trust in the employee? Then there is often room for that employee to take responsibility and thereby achieve a certain goal. Trust and Customers Customers must be able to trust their financial advisor. During office visits, we spoke with fd'ers about the customer journey. How do you get in contact with the customer and how do you maintain visibility of that contact? There are still many fd'ers who get their customers through local recognition and word-of-mouth advertising. In practice, this means that a customer who is satisfied with the service ensures that people in his environment are also pointed towards that fd'er. There is another side to the concept of trust. The AFM conducted research into mortgage fraud and it appeared that customers, and specifically fixers acting on behalf of these customers, in some cases abuse the trust of an fd'er. fd'ers can thereby unconsciously facilitate mortgage fraud. Based on our research into mortgage fraud, we have formulated a number of points of attention on the basis of which an fd'er can test if all controls have been done to prevent fraud.

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4. Market Data
3 These are, for example, banks and insurers.
In the spring of 2025, we sent out the questionnaire for the Market Monitor Advisors and Intermediaries (MMAB) and 5,695 holders of a license for financial services filled out this questionnaire completely.
The requested data provides information on 2024. Not all holders of a license for financial services receive a questionnaire for the MMAB. Holders who have a license by law3 (as of January 1, 2025, there were 341 of these) do not receive a questionnaire for the MMAB. In this paragraph, the AFM shares some outcomes from the questionnaire that give more insight into the fd-sector. Where relevant, we return to the outcomes of the questionnaire requests of previous years with these figures. The source of the tables is the license register, or the data comes from the license holders who filled out the questionnaire for the MMAB.
Figure 1 shows that the annual decline in the number of license holders continues. The relative amount by which the number of license holders declines is also increasing. On January 1, 2021, there were 2% fewer license holders than the previous year; on January 1, 2025, there were 3.5% fewer license holders than the previous year. This difference is caused by 245 new licenses granted in this period and 480 licenses withdrawn by fd'ers.
Figure 1. Number of holders of a financial services license per January 1 of each year
7,415
7,266
7,145
6,990
6,786
6,551
Source: AFM License Register. These figures include license holders who have a license by law.

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In Figures 2, 3, and 4, different categories of fd'ers are compared in various ways. These categories are classified by company size in FTE (full-time equivalents), where the smallest offices fall into the 0.1-1 FTE category and the largest offices into the >25 FTE category. From the figures below, it can be derived that there is clearly consolidation in the market.
Figure 2 shows that since 2020, the number of fd'ers in all categories, except the >25 FTE category, has decreased. Thus, there are relatively more large offices in the FD-sector compared to previous years.
Figure 2: Number of fd'ers by company size in FTE
3,000
2,000
2,500
1,500
1,000
2020 2021 2022 2023 2024
2,632 2,595 2,562 2,544 2,461
1,450
1,295 1,324 1,265 1,176
570 512 555 502 461
293 264 245 233 230
171 169 175 172 172
1,334
1,196 1,248 1,205 1,162

25 FTE 10.1-25 FTE 5.1-10 FTE 2.1-5 FTE 1.1-2 FTE 0.1-1 FTE Source: MMAB 2021-2025
Figure 3 shows that the market share held by these large offices is also growing. Was their market share in 2020 still 53.4%, in 2024 it was 59.5%. This goes mainly at the expense of the market shares of offices between 2.1 and 10 FTE. The bars in Figure 3 do not run to 100% because there are also fd'ers with 0 FTE: their market share lies around 1.5% per year.
Figure 3: Market shares based on revenue of groups of fd'ers by company size in FTE
Source: MMAB 2021-2025

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Figure 4 shows how revenue per FTE has developed over the past years. It is clear that in 2024 all categories show a clear increase in average revenue per FTE. The outlier here is again the >25 FTE category, which with an average revenue per FTE of €190,000, just passes the 10.1-25 FTE category.
Figure 4: Average revenue per FTE by company size in FTE
€ 0
€ 200,000
€ 140,000
€ 160,000
€ 180,000
€ 120,000
€ 100,000
€ 80,000
€ 60,000
€ 40,000
€ 20,000
2020 2021 2022 2023 2024
€ 155,000
€ 151,000
€ 126,000
€ 124,000
€ 107,000
€ 96,000
€ 190,000
€ 189,000
€ 154,000
€ 146,000
€ 128,000
€ 118,000

25 FTE 10.1-25 FTE 5.1-10 FTE 2.1-5 FTE 1.1-2 FTE 0.1-1 FTE Source: MMAB 2021-2025

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Table 1: Offered product categories against combinations of offered services
Advice Intermediation
None Management
Advice Intermediation
With Management
Execution
Only
Advice Only
Management Only
Power of Attorney
Consumer Credit 141 1,776 142 35 231 0
Mortgage Credit 212 3,321 67 49 112 0
Income Insurance 173 3,673 63 59 329 56
Pension Insurance 29 703 10 20 49 3
Private Damage Insurance 126 4,018 139 36 98 142 Business Damage Insurance 98 3,617 120 37 95 158 Wealth 306 3,802 142 109 712 18 Health Insurance 102 2,028 96 25 307 10 Source: MMAB 2021-2025 The table above shows that many fd'ers offer full services (advice, intermediation, and management) to their customers. Compared to all fd'ers, this means that a majority of all offices still offer total services for mortgage credit (58.3%), income insurance (64.5%), private damage insurance (70.6%), business damage insurance (63.5%), or wealth (66.8%).

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Figure 5: Source of revenue for groups of fd'ers by company size in FTE
Source: MMAB 2025
From the figure above, it appears that there are differences in where fd'ers in the different categories get their revenue from. The group of fd'ers up to and including 5 FTE is relatively very dependent on income from mortgage credit. Companies between 5.1 and 10 FTE lean increasingly on revenue from private damage insurance. For companies larger than 10.1 FTE, business damage insurance is also a significant source of income. Naturally, the distribution of income between different individual fd'ers can vary greatly, but in broad lines, it can be stated that as the fd'er gets larger, they become less dependent on revenue from mortgage credit compared to revenue from private damage insurance. The larger offices add revenue from business damage insurance here. This means that a setback in a sub-market in the FD-sector does not affect all fd'ers equally. For example, the declining revenue from mortgage credit in 2023 had vo