Dutch Authority for the Financial Markets urges audit firms to sharpen controls for high-risk clients and sets out two identification indicators

The Dutch Authority for the Financial Markets published supervisory observations from its 2025 work on audit firms focused on “high-risk clients”, sharing practical insights for firms to use to better identify and manage client-related risks that can affect the audit firm and statutory audit quality. The AFM notes that serving high-risk clients can have societal, organisational and personal consequences. Its work included a roundtable with mid-sized audit firms and individual discussions with smaller firms. For identifying high-risk clients, the AFM draws on data points from its statutory audit data request and applies two indicators: client characteristics (including activities in countries with a corruption index below 40 and current or past negative media coverage linked to suspected integrity violations) and client size, given the potentially higher societal impact of larger clients. Discussions with the sector also surfaced additional criteria audit firms use and approaches for mitigating client risks. The jointly developed insights have been shared with all audit firms holding a regular licence, alongside an expectation that firms identify and mitigate client risks in practice and reflect internally on the topic.