AFM Evaluation 2021-2025: Risk-Based Oversight Confirmed, Crypto Supervision Intensified

The Netherlands Authority for the Financial Markets (AFM) operates effectively and delivers measurable results across its supervisory mandate. That is the headline finding of the statutory five-year evaluation covering 2021 to 2025, which the Minister of Finance has now transmitted to both chambers of the Dutch parliament. The review also flags where the regulator can go further, with crypto supervision, cyber resilience, and sustainability oversight cited as areas where workload and cost have grown most sharply.

What the Evaluation Covers

Every Dutch independent administrative body (zbo) is assessed every five years on behalf of the responsible minister. This cycle covers efficiency, effectiveness, and whether the body's independent legal status continues to serve the public interest. For the AFM the review period runs from January 2021 through the end of 2025.

Scope and mandate examined

Researchers assessed the full range of statutory tasks: conduct supervision across capital markets, asset management, and retail financial services; licensing and registration; enforcement; and cross-border cooperation with European counterparts. The evaluation also looked at governance, cost management, and whether the regulator's organisational structure is fit for purpose.

Key Findings: What the Reviewers Said

Effectiveness confirmed across supervisory domains

The evaluation confirms the AFM carries out its legal obligations effectively and produces demonstrable outcomes. Reviewers found that risk-based supervision is firmly embedded and has been professionalised to a level that puts the AFM ahead of many comparable European supervisors. That is a meaningful benchmark: risk-based approaches require regulators to allocate limited resources toward the highest-probability and highest-impact harms, and the AFM's methodology is judged mature.

Cost discipline is present but pressures are real

The report acknowledges strong internal cost awareness and active management of efficiency. Costs did rise over the period, driven by new and more intensive supervisory mandates, crypto markets chief among them. Cyber resilience and sustainability disclosure have added to that load. Critically, the cost increase at the AFM is described as lower than at comparable supervisors, which suggests the efficiency controls are working even under expansion pressure.

Reviewers are direct about the limits of further cuts: reducing spend on staff, IT, or premises will almost certainly affect task delivery. Accounting firms and CFOs operating in the Netherlands should read this as a signal that the AFM is not in a position to de-prioritise any of its core mandates, including digital-asset oversight. For context on how the AFM has been applying its sanctions compliance guidance for accountants, that published work remains in force.

Crypto Supervision: A Growing Line Item

The evaluation explicitly names crypto as one of the drivers of increased supervisory intensity and cost. This is consistent with the AFM's published activity over the review window: registration requirements for crypto-asset service providers, thematic reviews, and cross-border cooperation within the MiCA framework all expanded substantially after 2022. The review does not suggest pulling back. It validates the resource commitment and points toward further professionalisation of oversight methods.

Firms registered with the AFM, or considering registration, should note that the evaluation endorses continued and deepening scrutiny. The AFM's supervisory review and evaluation process (SREP) market picture published separately sets out what that looks like in practice for firms subject to ongoing oversight.

Recommendations to Watch

Sharper risk identification

Reviewers see room to map risks more precisely and to improve how supervision is steered by that mapping. In practical terms this means the AFM is expected to refine its prioritisation model so that supervisory attention tracks actual market risk more dynamically. For firms, that translates into less predictable inspection cycles and more targeted, evidence-driven engagement from the regulator.

Better supervisory methods and information flows

The evaluation calls for continued development of supervisory methodology and the quality of risk information feeding into decisions. Firms that rely on good-faith engagement with the AFM benefit from this: clearer analytical frameworks tend to produce more consistent and proportionate supervisory outcomes.

Stronger cross-regulator collaboration

Reviewers recommend deepening cooperation with other Dutch and European supervisors. Given that crypto-asset markets are inherently cross-border, this is directly relevant to any firm active across multiple EU jurisdictions.

Independent Status Confirmed

The evaluation concludes that the AFM's status as an independent administrative body functions well and should continue. This matters for regulated firms: the operational independence of the supervisor from day-to-day ministerial direction is preserved, which supports consistent and legally robust enforcement decisions.

What This Means for Accounting Firms and CFOs

The evaluation does not introduce new obligations, but it signals the trajectory of supervision in the Netherlands clearly. Crypto oversight is a growth area for the regulator. Cost pressures will not reduce supervision intensity. Risk-based methods will become sharper, not softer. Firms operating in Dutch markets, or advising clients that do, should treat this as a baseline-setting document: the AFM's direction of travel is toward deeper, more analytically grounded oversight across all its mandates, including digital assets.

What is the AFM five-year evaluation?

It is a statutory review of the AFM's efficiency and effectiveness as an independent administrative body, conducted every five years on behalf of the responsible Dutch minister. The current evaluation covers 2021 to 2025 and has been sent to both chambers of parliament.

Does the evaluation change any regulatory requirements?

No. It assesses how the AFM performs its existing tasks and makes recommendations for improvement. It does not amend legislation or introduce new obligations for supervised firms.

Why did AFM costs increase during 2021 to 2025?

The evaluation attributes rising costs primarily to new and more intensive supervisory mandates, specifically crypto-asset oversight, cyber resilience requirements, and sustainability disclosure supervision. The report notes the cost increase is lower than at comparable European regulators.

What does risk-based supervision mean for firms under AFM oversight?

It means the regulator allocates supervisory attention based on the probability and potential harm of identified risks rather than applying uniform scrutiny to all firms equally. The evaluation finds this approach is well-embedded at the AFM and recommends it be sharpened further.

What are the main recommendations from the evaluation?

Reviewers recommend more precise risk mapping, better supervisory methods and information quality, and stronger cooperation with other Dutch and European supervisors. The AFM has stated it will act on the recommendations.

Source: AFM Netherlands