The document summarizes announcements from various supervisory authorities in the Netherlands regarding measures relating to COVID-19. It provides a table listing the date, supervisory authority, applicable legislation, summary of each announcement, and links to further information. The announcements include guidance from regulators such as the AFM and ESMA on issues like anti-money laundering processes, reporting obligations, financial reporting deadlines, and transparency calculations in light of difficulties posed by the pandemic. Financial regulators are providing clarification and extensions to help address COVID-19 impacts.

1. 0
Private & Confidentialosborneclarke.com
Date Supervisory
authority
Legislation Summary of announcement Link
source
14 April AFM MiFID2/MiFIR
AIFMD/UCITS
The AFM warns that, following investigations, investment
firms and fund managers must do more to combat money
laundering (AML) and counter terrorist financing (CTF).
According to the AFM, transactions must be monitored
more closely and suspicious transactions must be reported
earlier and better to the Financial Intelligence Unit (FIU-
Netherlands). Click here (EN) to register your institution at
FIU-Netherlands.
(NL) AFM website
10 April AFM
ESMA
MiFID2/MiFIR ESMA postpones the publication dates of the annual
transparency calculations for non-equity instruments and
for the quarterly systematic internaliser data for non-equity
instruments other than bonds. New date is set at 15 July.
(NL) AFM website
(EN) ESMA notice
9 April AFM
ESMA
AIFMD/UCITS Following a statement of ESMA, the AFM has announced a
grace period for AIFMD and UCITS managers to publish
annual and semi-annual reports due to COVID-19.
Nonetheless, fund managers are expected to inform both
the AFM and their investors of possible delay as soon as
possible, indicate the reasons for the delay and, as far as
possible, provide an estimate of the expected publication
date.
(NL) AFM website
(EN) ESMA notice
3 April AFM AIFMD/UCITS
MiFID2/MiFIR
AML
AFM issued some (generic) guidance on anti-money
laundering and counter terrorism financing (AML/CTF) risk
management processes for both investment firms and fund
managers in the light of COVID-19 risks and following
investigations of these processes at various institutions.
(NL) AFM website
(NL) AFM website
1 April AFM
ESMA
MiFID2/MiFIR AFM will apply the best execution reporting requirements
of RTS 27 and 28 deadlines less strictly, following a
statement of ESMA, insofar as delays have been caused
by the effects of the coronavirus.
(NL) AFM website
(EN) ESMA release
30 March AFM AIFMD/UCITS AFM supervises liquidity of funds, stresses that fund
managers must report to the AFM immediately suspending
redemption of units:
• activating gates;
• setting up side pockets;
• redemption in kind to investors.
(NL) AFM website
27 March ECB
DNB
Banks ECB and DNB ask banks not to pay dividends until at least
October 2020.
(EN) ECB website
(NL) DNB website
27 March AFM
ESMA
Issuers The AFM offers grace period for late filing of financial
reporting by issuers with financial instrument admitted to
trading following an ESMA statement.
(NL) AFM website
(EN) ESMA release
27 March ESMA MiFID2/MiFIR ESMA confirms 1 April as the application date of equity
transparency calculations (including the new tick sizes) –
despite some stakeholders asking ESMA to postpone the
date of application.
(EN) ESMA website
#COVID19
Financial regulators'​ COVID-19 measures
the Netherlands for
Investment firms and fund managers
Last update: 15 April 2020 – 12:00 AMS

2. 1
Private & Confidentialosborneclarke.com
Date Supervisory
authority
Legislation Summary announcement Link source
27 March ESMA Transparency
Directive
Publication deadlines under the Transparency Directive
(TD).
(EN) ESMA website
26 March AFM
ESMA
SFTR/MiFIR Postponement of the reporting obligations related to
securities financing transactions under the Securities
Financing Transactions Regulation (SFTR) and under
Markets in Financial Instruments Regulation (MiFIR).
(NL) AFM website
(EN) ESMA release
26 March AFM General
supervision
AFM has put on hold in principle all large information
requests from financial undertakings up to 1 June 2020.
(NL) AFM website
25 March EBA Various Clarifications for banks and consumers on the
application of the prudential framework in light of
COVID-19 measures.
(EN) EBA website
25 March ESMA Various (IFRS 9) Accounting implications of the COVID-19 outbreak on
the calculation of expected credit losses in accordance
with IFRS 9. Please note that EBA has also issued
related statements which are included in this list.
(EN) ESMA website
20 March DNB CRD/CRR Various DNB measures in reaction to coronavirus with
respect to capital and liquidity buffers.
(NL) DNB website
20 March ESMA Various ESMA extends consultations response dates. (EN) ESMA website
20 March ESMA MiFIR Actions to mitigate the impact of COVID-19 on the EU
financial markets regarding the new tick size regime for
systematic internalisers.
(EN) ESMA release
20 March ESMA MiFID2 Clarification of issues related to the application of
MiFID2 requirements on the recording of telephone
conversations.
(EN) ESMA website
17 March DNB CRR Decision to lower bank buffers requirements and
postponement of the implementation of a lower limit for
the risk weighting of mortgage loans.
(NL) DNB website
16 March ESMA Short Selling
Regulation
Temporarily obligation lower threshold to report net short
positions in shares are admitted to trading on a
regulated market in accordance with point (a) of article
28(1) of the Short Selling Regulation (SSR).
(EN) ESMA website
12 March ECB CRD ECB Banking Supervision provides temporary capital
and operational relief in reaction to coronavirus.
(EN) ECB website
11 March ESMA Various ESMA recommends action by financial market
participants for COVID-19 impact.
(EN) ESMA website
6 March DNB Various Guidance in respect of business continuity of financial
enterprises.
(NL) DNB website
Relevant sources:
Dedicated ESMA COVID-19 website here: https://www.esma.europa.eu/node/90557
Decicated AFM COVID-19 website here: https://www.afm.nl/nl-nl/professionals/onderwerpen/coronavirus-en-de-afm

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purposes only. They are not intended and should not be used as
a substitute for taking legal advice. Specific legal advice should
be taken before acting on any of the topics covered.
© Osborne Clarke N.V.
April 2020
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Johannes de Jong
Partner – Head of Financial Regulatory
T: +31 20 702 86 78
E: johannes.dejong@osborneclarke.com
Ted Broekhof
Associate – Financial Regulatory
T: +31 20 702 8690
E: ted.broekhof@osborneclarke.com
Matthijs Leijendekker
Associate – Financial Regulatory
T: +31 20 702 8914
E: matthijs.leijendekker@osborneclarke.com