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Financial Regulatory – Update Q1 2021

Traditionally, 1 January (and 1 July) each year is a date on which new Dutch financial regulations enter into force. This year, the amendments to the Dutch Financial Supervision Act are relatively few, but other developments are worthy of attention.

ESMA publishes report on licencing of fintech firms across europe

On 12 July, the European Securities and Markets Authority ("ESMA") published a report on the status of licencing regimes of FinTech firms across the European Union ("EU").

Digital Law Up(to)date: (1) Parliamentary initiatives about cyber attacks; (2) ‘Zero tariff’ options before the CJEU; and (3) Council of State, GDPR and encryption

In this blog, we briefly present three interesting matters in the field of digital law: (1) Parliamentary initiatives to tackle cyber attacks; (2) 'Zero tariff' options and open internet access do not mix; (3) Council of State, GDPR and encryption.

Digital operational resilience as key priority for financial institutions

Financial institutions and third party ICT providers will have to strengthen their IT security organisations, as the European Digital Operational Resilience Act is expected to be fully applicable in early 2025 after a two-year implementation period.

Cross-border gathering of evidence requires cross-border protection of legal professional privilege

On August 18, 2026, a European Regulation will enter into force that deals with the cross-border obtaining of electronic evidence in criminal cases (E-evidence Regulation).

DNB and AFM Joint Report on digital dependence in the financial sector

On 20 October 2025, the Dutch Central Bank and the Dutch Authority for the Financial Markets published a joint report on the current state of financial sector’s dependence on non-European IT Infrastructure.

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