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ARTICLE · 05 NOVEMBER 2021

Update: Dutch Implementation Of Investment Firm Directive

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The Investment Firm Directive is finally implemented into Dutch law. The requirements, amongst which in relation to initial capital and internal capital adequacy assessment process, apply as of 19 October.

NetherlandsFinance and Banking
Wendy Pronk
Wendy Pronk
Susanne Langenberg
Susanne Langenberg

The Investment Firm Directive is finally implemented into Dutch law. The requirements, amongst which in relation to initial capital and internal capital adequacy assessment process, apply as of 19 October.

Background

The Investment Firm Regulation (EU) 2019/2033 (IFR) and the Investment Firm Directive (EU) 2019/2034 (IFD) were adopted on 27 November 2019. For the legislative text of the IFR/IFD, see here and here. This new regime establishes a separate prudential framework for investment firms. Previously all investment firms fell under the CRR/CRD IV regime together with credit institutions. The new IFR/IFD regime also has consequences for managers of investment funds with a MiFID top-up, who are authorized to provide investment services.

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