Regulatory update :
the Netherlands
AFM publishes report on ICT recovery capabilities of asset managers
The AFM has published a report on 29 September 2026, highlighting the growing importance of robust ICT recovery capabilities within the asset management sector. As the risk of ICT disruptions and outages continues to increase, financial institutions must be able to restore critical systems, data, and processes swiftly and effectively following an incident.
The report is based on an assessment of five large institutional asset managers and examines how they have organised their ICT recovery frameworks and the extent to which they are prepared to recover from ICT disruptions or outages. According to the AFM, effective ICT recovery is a key component of operational resilience and is essential to ensuring the continuity of services.
The AFM encourages all asset managers to review the observations and lessons learned set out in the report and, where necessary, take appropriate measures to strengthen their own ICT recovery arrangements.
AFM publishes key observations following review of compliance and internal audit functions
The AFM published a report on 23 July 2026 setting out the results of its review of the organisation and effectiveness of the compliance and internal audit functions at management companies and managers of alternative investment funds.
The review, which was conducted in 2025 as part of a European Common Supervisory Action (CSA), sought to assess the extent to which fund managers have established effective compliance and internal audit functions. While the AFM identified a number of good practices across the sector, it also highlighted several areas for improvement.
In its report, the AFM shares a number of observations regarding both the organisational setup of these control functions and the manner in which they perform their responsibilities. The regulator expects fund managers to carefully consider the findings and, where appropriate, take measures to further strengthen their governance and control frameworks.
The publication underscores the AFM's continued focus on the quality and effectiveness of compliance and internal audit functions within the Dutch fund management sector.