Banks develop new disciplinary regime after rift
The Nederlandse Vereniging van Banken wants to establish a new system after Stichting Tuchtrecht Banken announced its withdrawal.
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The Nederlandse Vereniging van Banken is working on a new disciplinary system for bank employees. The move follows Stichting Tuchtrecht Banken’s decision to stop implementing banking disciplinary law, while hearings are reportedly resuming, according to the foundation.
The NVB writes that Stichting Tuchtrecht Banken ended the cooperation after it became clear that there was insufficient support for amended regulations. The banking association says it began developing a new system this summer, referred to as Tuchtrecht 2.0. According to the NVB, an orderly transition must protect the position of complainants, bank employees and ongoing cases.
Banking disciplinary law is linked to the bankers’ oath. In it, bank employees promise to act with integrity and due care. Tuchtrecht Banken investigates reports and can refer cases to an independent disciplinary committee. That committee can impose sanctions; appeals against a ruling can be made to the Banken Appeals Committee.
The rift follows a dispute over the independence and scope of the system. In April, ANP reported that disciplinary judges had partly suspended their work after the NVB proposed new regulations. Ongoing cases were to be completed, but new cases were not accepted at that point. Tuchtrecht Banken wrote at the time that new reports were still being dealt with, but that hearings could not be scheduled.
The NVB wants the renewed disciplinary system to focus more sharply on individually blameworthy conduct by bank employees. General banking policy and broader social debates about the sector should, according to the banking association, be handled by other regulators. The NVB also wants a uniform reporting policy, so that banks handle comparable potential disciplinary cases in the same way.
The statutory scope for self-regulation is not unlimited. Answers to parliamentary questions state that, under the Financial Supervision Act, banks must be subject to a disciplinary arrangement. De Nederlandsche Bank conducts risk-based supervision of compliance with those statutory conditions and can take enforcement action if necessary.
The forthcoming debate is therefore about more than an organisational change. The sector must design a system that is practically workable while also remaining credibly independent for employees, customers and complainants. The NVB has not yet published a fully developed set of new regulations. As a result, the precise transitional rules and the future role of the current foundation remain unclear.
One story, several perspectives
What is established
- The NVB is working on a new structure for banking disciplinary law.
- Stichting Tuchtrecht Banken has announced its withdrawal and says that hearings are resuming.
- The Financial Supervision Act requires banks to be subject to a disciplinary arrangement.
- DNB supervises compliance with the statutory conditions of that arrangement.
Left
Arguments A credible disciplinary system must be demonstrably independent of banks and allow structural failures to be investigated when individual employees are involved in them. Self-regulation is acceptable only with strong public safeguards and transparent avenues of appeal.
Values A balance of power, consumer protection, public oversight and institutional independence.
Consequences A more independent system could strengthen trust, but could be more costly for banks and more demanding to implement legally.
Centre
Arguments The key is a workable system with a clear division of responsibilities: disciplinary proceedings for individual conduct, supervision for systemic risks and policy. The sector may organise it in practical terms, as long as the legislature and DNB monitor the framework conditions.
Values Proportionality, legal certainty, expertise and administrative feasibility.
Consequences A clear delineation could speed up proceedings, but requires good cooperation between the disciplinary committee, banks and regulators.
Right
Arguments Professional sectors know their own standards best and should not depend on the government for every integrity issue. Banks can build a new system more quickly and efficiently, provided it meets the statutory requirements.
Values Self-regulation, responsibility of the sector, efficiency and competitiveness.
Consequences A sector-led solution could operate more quickly and be less bureaucratic, but risks being seen as interest representation if it does not operate visibly independently.
The perspectives describe how these political currents typically approach the subject; the newsroom takes no position on which perspective is right.
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The NVB’s current step, the earlier work stoppage and the statutory supervisory framework have been confirmed by public sources. Unpublished details about the new structure have not been presented as facts.
- confirmed The NVB is working on Tuchtrecht 2.0 after Stichting Tuchtrecht Banken ended the arrangement. — The NVB describes this in a report dated 25 September 2026. source
- confirmed Stichting Tuchtrecht Banken implements banking disciplinary law and facilitates disciplinary and appeals committees. — This is stated on the foundation’s website. source
- confirmed Disciplinary judges partly suspended their work in April 2026. — ANP reported this and referred to confirmation by the foundation. source
- confirmed DNB supervises the statutory conditions for banking disciplinary law. — This is stated in the answers to parliamentary questions. source
Editor's note
The NVB’s current position and the earlier suspension of hearings can be found directly in public sources. The full new regulations and the definitive transitional arrangement have not yet been published.Sources
- Bankensector maakt plan voor Tuchtrecht 2.0 — Nederlandse Vereniging van Banken
- Maak melding: uitleg over lopende dossiers — Tuchtrecht Banken
- Rechters bankentuchtrecht gaan in staking — ANP via ZeelandNet
- Beantwoording Kamervragen over bankentuchtrecht — Tweede Kamer der Staten-Generaal
More on this in Dutch media
- NOS — „banken tuchtrecht”
- Het Parool — „banken tuchtrecht”
- de Volkskrant — „banken tuchtrecht”