Dutch Authority for the Financial Markets issues an instruction to Onafhankelijk Vermogensbeheer ’s Gravenhage over suitability, product governance and cost transparency failings

The Dutch Authority for the Financial Markets has published an enforcement update on an instruction imposed on 29 September 2025 on Onafhankelijk Vermogensbeheer ’s Gravenhage B.V. (OVG) after an investigation found multiple shortcomings in compliance with investor protection rules on suitability, the product approval and review process (PARP) and cost transparency. The AFM found serious deficiencies in OVG’s suitability framework, including instances where it did not collect sufficient information on clients’ financial position and lacked appropriate policies and procedures to assess portfolio risk because it did not measure and actively monitor that risk. In its PARP arrangements, OVG’s target market descriptions were insufficiently detailed, limiting its ability to ensure products were only offered to clients within the intended target market. On cost transparency, OVG did not provide personalised cost information when entering into an agreement and did not disclose the total cost amount as a percentage upfront, leaving clients without a clear and complete picture of the costs they would pay. The instruction is intended to ensure that breaches are remediated within a set period. OVG has taken steps to strengthen legal and regulatory compliance and its compliance function, committed to implementing the measures required by the AFM, and did not file an objection. The case stems from supervisory work conducted from 2024 as part of a broader AFM review of compliance with investor protection rules at smaller investment firms.