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AFM update on SREP for investment firms

By Floortje Nagelkerke (NL) & Julia van der Grint on June 23, 2026
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On 17 June 2026, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, AFM) published its Supervisory Review & Evaluation Process (SREP) market overview 2025.  The SREP is a periodic survey that investment firms are required to complete, of which the results are used by the AFM to develop a market overview that supports its supervision. This market overview provides feedback on the evaluation of the responses of a questionnaire sent to 239 investment firms in the fall of 2025.

The AFM highlights the following findings of its market overview:

  • Many firms’ policies and processes (i.e. compliance, regulations and professional competence) are well organised. Simultaneously, however, execution of these policies and processes is not strong enough. This creates the risk that policy looks sound on paper, but does not work sufficiently in practice;
  • IT risk management is falling short, which makes organisations vulnerable to cybercrime;
  • Greater clarity on the division of roles and responsibilities within organisations is required. 

The AFM expects market participants to use the insights from the SREP market overview to critically evaluate their organisations and identify areas where their business operations can be improved. In September 2026, the AFM will issue a new SREP request to investment firms.

The full SREP market overview 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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