Dutch Authority for the Financial Markets publishes updated mortgage advice guidance emphasising adviser independence, proportionality and new sustainability and relationship breakdown topics

The Dutch Authority for the Financial Markets (AFM) has published an updated Mortgage Advice Guidance (Leidraad Hypotheekadvisering) setting out practical expectations for mortgage advisers on delivering suitable advice on mortgage credit. The revised guidance places greater weight on the adviser’s independent professional role, requiring advisers to critically assess customer preferences and provide a substantiated recommendation aligned to the customer’s personal circumstances, consistent with the legal advice standard in Article 4:23 of the Financial Supervision Act (Wft). The guidance covers the full advice process from initial contact to aftercare and adds a stronger focus on probing inconsistencies in customer information and making assumptions explicit where data is incomplete. It reiterates that the document is a support tool rather than a checklist, with proportionality as a core principle so the depth of work is tailored to each customer situation. At the market’s request, the AFM also adds new themes on sustainability, including mapping options, financing routes and potential financial implications, and on relationship breakdown, including the need to clearly discuss risks and personal consequences. A draft version was previously consulted on and generated 23 responses, with a feedback statement outlining how input was incorporated; the AFM will continue engaging with market participants and monitoring whether consumers receive suitable advice.