The Dutch Authority for the Financial Markets has published supervisory findings on the compliance and internal audit functions of Dutch managers of investment institutions, based on a review conducted as part of a European Securities and Markets Authority-coordinated Common Supervisory Action. While many managers have these functions broadly in place, the review found that improvements are still needed in the quality of compliance documentation, control over outsourced work, and the justification for organizational choices made on proportionality grounds. The authority expects managers to use these findings to strengthen governance and internal controls. On compliance, documents such as monitoring plans and reports were sometimes outdated, incomplete or too generic, and planning, monitoring and reporting did not always align, creating a risk that shortcomings are not identified or followed up in time. On outsourcing, the authority found that many managers use external providers for compliance or internal audit work, but some rely too heavily on them even though responsibility remains with the manager. Firms should retain sufficient internal knowledge and involvement and actively direct how those tasks are carried out. On proportionality, managers often did not adequately substantiate decisions such as combining functions or organizing internal audit differently. They should be able to explain why the chosen setup fits the nature, size and complexity of the organization and maintain a clear separation between operational work and control functions. The Dutch Authority for the Financial Markets said it will continue to incorporate these topics and findings into its supervision. The findings also feed into the broader European Securities and Markets Authority Common Supervisory Action on the design and operation of compliance and internal audit functions at managers.
Dutch Authority for the Financial Markets2026-07-23
Dutch Authority for the Financial Markets identifies gaps in managers' compliance documentation, outsourcing oversight and proportionality rationale
The Dutch Authority for the Financial Markets published findings from a review of compliance and internal audit functions at Dutch managers of investment institutions under an European Securities and Markets Authority Common Supervisory Action. It found weaknesses in compliance documentation, oversight of outsourced control functions and the rationale for proportionality-based structures. The authority will continue to reflect those issues in its supervision.