Dutch CRD VI Implementation Act Enters Into Force, Introducing New Assessment Framework for Key Function Holders
On 22 September 2026, the Capital Requirements Implementation Act 2026 (*Implementatiewet Kapitaalvereisten 2026*) entered into force in the Netherlands, transposing the sixth Capital Requirements Directive (CRD VI, Directive (EU) 2024/1619) into Dutch law. The Act follows the Capital Requirements Regulation and introduces a new assessment framework for Key Function Holders at regulated institutions.
Why this matters
CRD VI is a significant overhaul of EU bank governance rules, and the Netherlands is among the first member states to complete transposition. The new Key Function Holder assessment framework raises the bar for fitness-and-propriety reviews at Dutch-regulated banks and investment firms. Institutions operating cross-border into the Netherlands face immediate compliance obligations.
On the Ground
The live Act triggers regulatory compliance and financial services advisory work: reviewing governance frameworks, updating appointment and assessment procedures for senior managers, and advising on interactions with the Dutch Central Bank (DNB). A trainee would assist by tracking transposition status across EU member states, drafting compliance checklists against the CRD VI requirements, and reviewing client governance documents for gaps.
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