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ARTICLE · 20 FEBRUARY 2025

Stricter Outsourcing Rules For Financial Service Providers

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On January 23, 2025, the Ministry of Finance published the Financial Markets (Amendment) Decree 2026 (Amendment Decree) for consultation.

LuxembourgFinance and Banking
Martijn Schoonewille
Martijn Schoonewille
Wendy Pronk
Wendy Pronk
Rosalie Tielens
Rosalie Tielens

On January 23, 2025, the Ministry of Finance published the Financial Markets (Amendment) Decree 2026 (Amendment Decree) for consultation. The Amendment Decree is a comprehensive decree in the field of financial markets and provides (amongst other) further rules on outsourcing for financial service providers.

In this blog, we will discuss the relevant aspects of the Amendment Decree for financial service providers.

Current legal framework for outsourcing

Financial undertakings can outsource certain activities. The rules on outsourcing for financial undertakings fall under the Dutch act on the financial supervision (Wet op het financieel toezicht, AFS) and focus on activities that are part of or arise from the core activities of financial undertakings. The responsibility for compliance with the laws and regulations remains with the financial undertakings that outsource their activities. The Dutch Financial Markets Authority (Autoriteit Financiële Markten, AFM) pl

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