Dutch Authority for the Financial Markets publishes investor protection improvement points for smaller asset managers after risk-based reviews

The Dutch Authority for the Financial Markets has published a set of improvement points for smaller asset managers after identifying risks in their compliance with investor protection standards. The measures draw on risk-based supervisory work carried out in 2024 and 2025 at a number of smaller investment firms and are presented as relevant more broadly across the sector. The improvement points are structured around seven areas: suitability assessments and documentation, including active client fact-finding and evidence of how information fed into portfolio decisions; product approval and review processes (PARP), including target market definition, scenario analysis and periodic evaluation; demonstrable staff competence, via DSI registration or an equivalent that firms can substantiate; cost transparency before and after service provision and timely, clear communication of changes; conflicts of interest controls, particularly where firms offer their own instruments and face volume or margin incentives; prompt reporting to the AFM of incidents and material changes, including integrity and information security incidents; and an adequately designed compliance function with ongoing monitoring, clear responsibilities and sufficient expertise, with accountability retained even when outsourced. The AFM’s accompanying publication, “Meeting investor protection standards: what does this mean for you?”, provides the full set of improvement points and additional explanation. Firms are encouraged to review the points and make changes where needed, supported by earlier AFM guidance and the regulator’s information on ongoing obligations.