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AFM and DNB report on digital dependency in the financial sector

By Floortje Nagelkerke (NL) & Julia van der Grint on October 21, 2025
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On 20 October 2025, the Dutch Authority for Financial Markets (Autoriteit Financiële Markten, the AFM) and the Dutch Central Bank (De Nederlandsche Bank, DNB) published a report about digital dependency in the financial sector. The key message is that the Dutch financial sector faces systemic risks as it has a growing reliance on a limited number of non-EU IT providers. The regulators identify several dependency risks, assess how these are managed and set out the applicable legal and regulatory framework in relation to digital dependency.

The financial sector increasingly depends on external IT service providers and cloud environments, which leads to concentration and systemic risks. These risks are especially present where geopolitical developments may result in that dependence being exploited by state actors. Another risk is ‘vendor lock-in’, as migrating to another system is more complex once an entity operates within a specific ecosystem. Cyber attacks continue to pose a risk, the impact of which has increased significantly over time. Finally, outsourcing data storage and processing to cloud service providers raises issues around data protection, supervision, and compliance. The AFM and DNB have applied a scenario analysis, from which it follows that a stronger EU tech sector is necessary to prevent the EU from being vulnerable to technological disruptions resulting from geopolitical disruptions.

The AFM and DNB find that financial institutions are aware of these risks, but that often, an EU alternative with the same quality as non-EU tech providers, such as cloud service providers, is lacking. Where financial institutions can choose from multiple vendors, they will do so. They do not deem it feasible or realistic to switch to their own data centres or co-location. Financial institutions apply risk management regarding IT risks, closely map which (sub-)contractors and chain partners their primary supplies work with and have exit and business continuity plans in place regarding critical third parties.

The Digital Operational Resilience Act (Directive (EU) 2022/2554, DORA) aims to manage the risks associated with third-party IT service providers. The most critical IT supplies at EU level are subject to supervision under DORA. Although the current legal and regulatory framework contribute to this risk management, vulnerabilities remain. On the short term, financial institutions should take measures to prepare for disruptive scenarios and to mitigate the potential impact where possible. In the longer term, the EU should become less dependent on non-EU IT providers and achieve a greater degree of digital autonomy, among others by developing EU alternatives. The AFM and DNB suggest that EU policymakers should consider establishing a cross-sectoral European cloud regulator.

The report is available here (Dutch only).

Photo of Floortje Nagelkerke (NL) Floortje Nagelkerke (NL)
Read more about Floortje Nagelkerke (NL)Email
Photo of Julia van der Grint Julia van der Grint

Julia van der Grint is a financial services lawyer based in Amsterdam.

She advises clients on a wide range of regulatory and compliance aspects relevant to financial institutions, such as investment firms, trading platforms, payment institutions, insurers, fund managers and clearing and settlement…

Julia van der Grint is a financial services lawyer based in Amsterdam.

She advises clients on a wide range of regulatory and compliance aspects relevant to financial institutions, such as investment firms, trading platforms, payment institutions, insurers, fund managers and clearing and settlement institutions. Julia has developed particular knowledge of blockchain and cryptocurrencies, and advises crypto-asset services providers, crypto exchanges, payments providers and financial institutions on the regulatory issues related to the deployment of these technologies. She also advises on Dutch licence application and notification requirements and assists companies in their licence or notification processes with the Dutch Authority for Financial Markets and the Dutch Central Bank. Additionally, she assists companies in their contacts with these supervisory authorities and represents companies in enforcement procedures.

In addition, she has previously advised banks, other financial institutions and corporates in an array of transactions, both domestic and cross-border. This includes, among others, advising lenders and lender-groups in corporate restructurings and other insolvency related matters.

Prior to joining the team as an associate, Julia gained experience with the Amsterdam office as a student worker.

Read more about Julia van der GrintEmail
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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Global Regulation Tomorrow
  • Organization:
    Norton Rose Fulbright
  • Article: View Original Source

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