DNB and the AFM apply existing, technology-agnostic financial law to AI rather than a separate Dutch AI rulebook. DNB's July 2019 discussion paper set out the 'SAFEST' principles (soundness, accountability, fairness, ethics, skills, transparency), and the joint AFM and DNB report of 9 April 2024 states that institutions are expected to use AI responsibly and that existing regulations continue to apply in full. The report expects the two authorities, as the existing financial regulators, to take on supervision of the EU AI Act for financial services, and the AFM's Agenda 2026 (19 January 2026) says it is expanding AI supervision.
| Full name | De Nederlandsche Bank (DNB) and the Netherlands Authority for the Financial Markets (AFM) |
| Role | Dutch prudential and conduct supervisors that publish joint AI positions and apply existing financial law to AI |
| Force on banks | Supervisory guidance |
| Applies to | Dutch banks, insurers, pension funds, investment firms and asset managers; DNB's SAFEST principles are addressed to financial firms generally and the 2024 joint report to the Dutch financial sector |
| Key document | AFM and DNB, 'The impact of AI on the financial sector and supervision' (9 April 2024), building on DNB's 'General principles for the use of Artificial Intelligence in the financial sector' (25 July 2019) |
| Latest move | 19 January 2026: the AFM announced in its Agenda 2026 that it will intensify supervision of the responsible use of AI and of DORA compliance; April 2026: AFM report on AI in the Dutch asset management sector |
| Documents tracked | 2 · all documents → |
DNB's 2019 paper says soundness is the aspect of AI that is of DNB's primary prudential concern. The 2024 joint report applies sound and ethical operational management, the duty of care, product-development and distribution standards and rules to prevent excessive borrowing to AI-supported services, identifies specific AI-related provisions in MiFID II/MiFIR algorithmic trading rules, the revised Consumer Credit Directive and automated-advice rules, and notes that CRR internal-model requirements contain many specific requirements that AI models must also meet.
The AFM's Agenda 2026, announced on 19 January 2026, asks institutions to map their AI applications, strengthen model risk management and data quality, record decision-making logic and actively report incidents, and links AI supervision to its DORA priorities. In April 2026 the AFM published a survey-based report on AI in Dutch asset management (323 institutions surveyed; 53% already using AI or aiming to within a year).
What has the DNB / AFM actually published on AI?
| Date | Document | Status |
|---|---|---|
| Apr 9, 2024 | AFM and DNB report on the impact of AI — The impact of AI on the financial sector and supervision | Final |
| Jul 25, 2019 | DNB SAFEST AI principles — General principles for the use of Artificial Intelligence in the financial sector | Final |
| Date | Type | Document / event |
|---|---|---|
| Apr 2026 | Milestone | AFM publishes report on AI in the Dutch asset management sector. Survey of 323 institutions: about half (53%) already use AI or aim to within a year, mainly for data analysis and information processing; the AFM expects asset managers to manage explainability risks and be transparent with clients about the role of AI. |
| Jan 19, 2026 | Milestone | AFM Agenda 2026 expands AI supervision. The AFM announced that in 2026 it will intensify supervision of digital resilience and the responsible use of AI, asking institutions to map their AI applications, strengthen model risk management and data quality, record decision-making logic and report incidents. |
| Apr 9, 2024 | Report | AFM and DNB report on the impact of AI — The impact of AI on the financial sector and supervision. The joint AFM and DNB report 'The impact of AI on the financial sector and supervision', published on 9 April 2024, states that financial institutions are expected to use AI responsibly and that existing regulations continue to apply in full. source ↗ |
| Jul 25, 2019 | Consultation | DNB SAFEST AI principles — General principles for the use of Artificial Intelligence in the financial sector. DNB's discussion paper 'General principles for the use of Artificial Intelligence in the financial sector', published on 25 July 2019, is the origin of the 'SAFEST' principles: soundness, accountability, fairness, ethics, skills and transparency. source ↗ |
- Which authority or authorities the Netherlands designates for AI Act supervision of financial services; the 2024 report expects the current AFM/DNB split of supervision to apply
- DNB's and the AFM's thematic examinations and sector inquiries on AI, including insurers
- Further AFM and DNB guidance on explainability, model risk and data quality as foreshadowed by the Agenda 2026
What are DNB's SAFEST principles?
SAFEST stands for soundness, accountability, fairness, ethics, skills and transparency. DNB set out 17 numbered principles under these six headings in a discussion paper published on 25 July 2019, framed as preliminary views within the Financial Supervision Act's requirement for sound and controlled business operations, with proportionality applying.
Is there a separate Dutch law on AI in banking?
No. The AFM and DNB report of 9 April 2024 says supervision objectives and standards are technology-agnostic, that existing financial legislation applies to AI, and that specific references to AI in current financial regulation are limited.
Who supervises the EU AI Act for Dutch banks?
The 2024 report states that, where AI is used for financial services, the principle underlying the AI Act is that existing financial regulators (AFM and DNB) also monitor compliance, and that the current split of supervision between them is expected to apply. Check current national designation decisions for the final allocation.
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