On 12 June 2026, the Dutch Central Bank (De Nederlandsche Bank, DNB) issued a news update on the fixed overhead requirement (FOR) for investment firms. Based on research conducted by DNB, it finds that in practice, a number of deductible items of the FOR are incorrectly applied across the sector.
DNB specifically lists the following items as those where mistakes commonly occur:
- Bonuses and variable remuneration: the conditions for variable remuneration are not always contractually stipulated or are insufficiently linked to the net profit of the investment firm.
- Non-recurring expenses from non-ordinary activities: both conditions, that an expense is ‘non-recurring’ and stems from ‘non-ordinary activity’, must be met for an item to be deductible as a non-recurring expense from non-ordinary activities.
- Expenses incurred by third parties: expenses incurred by third parties (e.g. the parent undertaking) for activities that are necessary for the operation of the undertaking (e.g. office expenses), but which are not charged to the investment firm, must be added to the total expenses of the investment firm.
Call to action
DNB calls on investment firms to critically review their FOR calculation and their application of deductible items and announces that it will clarify its previously shared guide, pay extra attention to the FOR, keep actively informing the sector on the application of the FOR, and will take enforcement action where capital and/or liquidity shortfalls occur as a result of the incorrect application of the FOR.
The news update is available here (Dutch only).