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Nederlandse Vereniging van Banken / Dutch Banking Association

NVB

The Dutch Banking Association represents around 65 banks in the Netherlands and advocates for a service-oriented, sustainable and internationally competitive banking industry at the EU level.

Lobbying Activity

Meeting with Auke Zijlstra (Member of the European Parliament, Shadow rapporteur)

12 Jan 2026 · Securitisatie

Meeting with Auke Zijlstra (Member of the European Parliament, Shadow rapporteur)

9 Dec 2025 · Digital euro

Meeting with Fernando Navarrete Rojas (Member of the European Parliament, Rapporteur)

21 Nov 2025 · EURO DIGITAL

Meeting with Dirk Gotink (Member of the European Parliament)

20 Nov 2025 · Digital Euro

Meeting with Bas Eickhout (Member of the European Parliament)

20 Nov 2025 · Digital Euro

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Oct 2025 · Sustainable finance framework and circular economy

Meeting with Auke Zijlstra (Member of the European Parliament)

18 Sept 2025 · Payment Services Regulation

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

4 Sept 2025 · PSR

Meeting with Dirk Gotink (Member of the European Parliament) and Construction Products Europe

4 Jun 2025 · Housing

Meeting with Rachel Blom (Member of the European Parliament)

4 Jun 2025 · Position Housingcrises EU

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

27 Feb 2025 · Taxation of financial services

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

9 Jan 2025 · EU-UK Financial Regulatory Forum

Meeting with Lara Wolters (Member of the European Parliament)

2 Oct 2024 · Banking

Meeting with Dirk Gotink (Member of the European Parliament)

25 Sept 2024 · Bankenwetgeving

Meeting with Auke Zijlstra (Member of the European Parliament)

25 Sept 2024 · Banking

Meeting with Anouk Van Brug (Member of the European Parliament)

23 Sept 2024 · Courtesy call

Meeting with Michiel Hoogeveen (Member of the European Parliament, Shadow rapporteur)

27 Nov 2023 · Digital euro

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and ING Group

17 Nov 2023 · CSDDD

Meeting with Esther De Lange (Member of the European Parliament)

24 Oct 2023 · Payment Services - APA

Meeting with Lara Wolters (Member of the European Parliament, Rapporteur) and Global Network Initiative

24 Oct 2023 · Staff level: CSDD Directive

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

3 Jul 2023 · Climate agenda of the EU

Response to Enhancing the convergence of insolvency laws

15 Mar 2023

Please find the feedback by the Dutch Banking Association in the document attached.
Read full response

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Esther De Lange (Member of the European Parliament)

28 Feb 2023 · AML Package - APA

Meeting with Tom Berendsen (Member of the European Parliament)

6 Feb 2023 · EPBD - Meeting with APA

Meeting with Esther De Lange (Member of the European Parliament)

21 Sept 2022 · AML - APA

Meeting with Esther De Lange (Member of the European Parliament)

16 Jun 2022 · Banking Package

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and Commerzbank AG

14 Jun 2022 · CRR (staff)

Meeting with Paul Tang (Member of the European Parliament, Rapporteur)

31 May 2022 · Meeting on Anti-Money Laundering Package and other FISC and ECON related files

Meeting with Esther De Lange (Member of the European Parliament)

22 Apr 2022 · AML Package - APA

Meeting with Paul Tang (Member of the European Parliament, Rapporteur) and Nordea Bank Abp

20 Apr 2022 · Event on Private Public Partnerships in relation to AML

Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur) and Bundesnotarkammer

20 Apr 2022 · AMLR

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and

6 Oct 2021 · Basel III

Response to Consumer Credit Agreement – review of EU rules

2 Sept 2021

The Dutch Banking Association (DBA) would like to make some additional remarks on the Consumer Credit Directive (CDD) proposal. These remarks come in addition to the reaction of the European Banking Federation (EBF). Response per item described • Scope The DBA has concerns about the expansion of the scope of the CCD and thus a plentitude of requirements for all products, including low-risk credits such as overdraft facilities and charge cards. We fear that this may lead to high costs for consumers and a disproportional burden for credit providers. If for example creditworthiness assessments must be performed in each case of an application for a low-risk overdraft facility, it will lead to high costs and eventually to having credit providers end these products. Should the scope of the CCD be broadened to more low-risk and/or short term credits, such as overdraft facilities and charge cards, we propose to make more clear in Article 18 of the Proposal, what exactly is required for the creditworthiness assessment for these kinds of products in order to keep the assessment proportionate. • Non discrimination According to Article 6 of the Proposal, credit providers are not allowed to discriminate on grounds of nationality or legitimate place of residence. We have concerns about the practical application where it concerns the credit provider’s discretion. In our view, it should be clarified that this Article should not affect creditors’ discretion in assessing the consumers’ creditworthiness and the discretion to decide to grant the loan or not. Even though Article 19 of the Proposal requires access for creditors to databases in all Member States in order to assess creditworthiness in cross-border situations, it is questionable whether such a provision will work (and when it will be working). Also, it is not clear in which country’s database the credit should be registered: the Member State in which the consumer resides or the Member State in which the credit provider is based? These uncertainties may cause credit providers not to be aware of loans provided to a consumer in other Member States. This creates a risk for the consumer of overindebtedness, without the possibility of credit providers to assess this risk. Furthermore, it remains to be seen how documents of proof (e.g. proof of income) in a foreign language and based on different customs/rules (e.g. specific codes) can be verified by credit providers. We doubt when applying for a loan in another Member States consumers will fully understand the credit product and processes, in particular if documentation is in a foreign language. In addition, it should be considered that credit providers have no access to foreign anti-fraud systems and other databases. • Tying and bundling Article 14 (Tying and Bundling) is not very clear and may be clarified. We suggest that in article 14, paragraph 2, the word “only” will be scrapped, or that a clear exception will be made for (common) checking accounts. This would be to the benefit of consumers, who have a checking account tied to or bundled with a loan, and may want to use it for payments not directly related to the loan agreement. • Pre-contractual information Instead of reducing the existing pre-contractual information requirements (SECCI), another document is added (SECCO). We strongly advise reducing the amount of information that must be provided in advertisements and allowing credit providers to refer to a document or to a website, which contains all information required. • Alignment with the GDPR With respect to profilin or other automated processing of data, we stress that this does not always concern solely ‘automated decisionmaking’ as mentioned in Article 22 GDPR. ‘Automated processing of data’ is not the same as ‘automated decisionmaking’. However, the requirements of Article 18(6) and (7) of the Proposal are quite similar to, and may even go further than, the requirements of Article 22 GDPR.
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Meeting with Roberto Berutti (Cabinet of Commissioner Janusz Wojciechowski) and Rabobank and Land- en Tuinbouw Organisatie Nederland

9 Jun 2021 · Basel 4 impact on agricultural entrepreneurs

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

7 Jun 2021 · Basel III

Response to Law enforcement access to the interconnection of national centralised bank account registers and data retrieval systems

28 Apr 2021

The proposed amendment to the roadmap would imply that (designated) law enforcement agencies should gain “to get direct access to information on the identity of holders of bank and payments accounts in other Member States” and that “Smooth and fast access to the information found in the registries held by other Member State would provide direct operational support to law enforcement authorities, including AROs and strengthen their effectiveness and efficiency”. At present access to such information is subject to (bilateral) cooperation agreements, which by definition contain certain safeguards vis-à-vis legal grounds for such requests (note that not all jurisdictions apply the same basis for access to such information) as well as certain proportionality checks. In extension to this, note that access to the national bank account registries is limited to those parties having the proper legal standing as well as having applied the proper request under national law. This proposal seems to circumvent such safeguards and would imply access without checks as to the nature of the request. Whilst the need for quick access is certainly recognised, direct access without the aforementioned safeguards seems an undesirable approach. Rather we would plead for a simplified procedure for such requests but with the condition that it would still need to be submitted by the relevant local authority, thus maintaining the proper legal grounds for access to the bank registries both from a local criminal law perspective, as well as with a view of providing adequate safeguards for EU citizens that their information would only be accessed when adequate (legal) grounds exits. Also, it should be noted that unfettered access by non-national law enforcement agencies not only posed potential proportionality issues (legitimacy of access, nature of access and frequency of access), but also technical and financial issues concerning the nature of the infrastructure and the financial costs for maintaining such access which would undoubtedly lead to a substantial (exponential) increase in demands, which is not envisioned at present. Finally, the question of audits into the validity of non-national requests would pose material issues.
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Meeting with Mairead McGuinness (Commissioner)

11 Jan 2021 · How to Rebuild the Economy

Response to Review of the VAT rules for financial and insurance services

19 Nov 2020

Please find as attachment the feedback from the Dutch Banking Association. Kind regards Ton Daniels Senior Advisor Tax & Risk at the Dutch Banking Association.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

2 Jul 2020

The NVB would like to respond to the proposed amendments regarding Suitability and Product Governance, consolidated in one reaction. Please find our response attached.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

2 Jul 2020

The NVB would like to respond to the proposed amendments regarding Suitability and Product Governance, consolidated in one reaction. Please find our response attached.
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Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

5 Feb 2020 · EU Anti-Money Laundering action plan; Public private partnerships in the Netherlands to promote exchange of information on anti-money laundering

Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

The Dutch Banking Association (Nederlandse Vereniging van Banken, or ‘NVB’) welcomes the opportunity to comment on the amendments to MiFID II delegated act, which is part of the Commission proposals on financing sustainable growth (‘Commissions package’). In essence, the NVB endorses the intention behind the Commissions package’s goals. The SDG’s and Paris Agreements present a clear dot on the horizon for banks and the Commissions package could create some important guidance for increased sustainable investing. However, we do have serious concerns on both timing and method that might lead to unintended and unforeseen consequences. Please find attached our complete reaction.
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Meeting with Frans Timmermans (First Vice-President)

1 Mar 2016 · Better regulation agenda