Peer Review of the Netherlands

21 November 2025 | PDF full text (595 KB)

Despite the maturity of the Netherlands’ cyber resilience practices, the interconnectedness of the financial system and the continued evolution of cyber threats calls for a continued focus and further enhancements.

The Netherlands has made significant progress in enhancing cyber resilience within its financial sector, reflecting its strong commitment over many years. It has developed several market leading practices such as the Threat Intelligence-Based Ethical Red-teaming (TIBER) and Advanced Red Teaming (ART) frameworks. Dutch authorities and government agencies demonstrate high levels of cooperation and information sharing with each other and with the industry. Industry actively contributes to the comprehensive gathering and sharing of threat intelligence, and a national-level crisis-management structure brings together financial authorities to ensure coordination and collaboration during major operational disruptions.

Despite the maturity of the Netherlands’ cyber resilience practices, the interconnectedness of the financial system and the continued evolution of cyber threats calls for a continued focus and further enhancements. The FSB recommends that:

  • Dutch authorities regularly review the purpose and membership of the groups established for information sharing with the industry to ensure they remain efficient and effective, and explore ways to enable rapid information sharing during a crisis;
  • De Nederlandsche Bank (DNB) continues to support the take-up of ART testing by developing strategies to ensure more financial entities are sufficiently mature to conduct a form of cyber resilience / red teaming testing such as ART;
  • Dutch authorities continue efforts to establish national analysis of existing registers of information to identify critical third-party providers in the Netherlands, assess concentration risks and define a strategy to address domestically critical third parties.

FSB encourages the Netherlands to continue strengthening cyber resilience in its financial sector

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Ref: 22/2025

  • Peer review finds Dutch authorities have been long committed to enhancing the financial sector’s cyber resilience and developed several leading practices.
  • Dutch authorities and government agencies demonstrate high levels of cooperation and information sharing with each other and with the industry.
  • The FSB recommends that Dutch authorities regularly review information sharing mechanisms, promote expanded cyber resilience testing and establish a national analysis of third-party risks.

The Financial Stability Board (FSB) today published its second Peer Review of the Netherlands, examining the country’s efforts to enhance cyber resilience in the financial sector and mitigate financial stability risks arising from operational incidents and cyber-attacks.

The Netherlands has made significant progress in enhancing cyber resilience within its financial sector, reflecting its strong commitment over many years. It has developed several market leading practices such as the Threat Intelligence-Based Ethical Red-teaming (TIBER) and Advanced Red Teaming (ART) frameworks. Industry actively contributes to the comprehensive gathering and sharing of threat intelligence, and a national-level crisis-management structure brings together financial authorities to ensure coordination and collaboration during major operational disruptions. 

Despite the maturity of the Netherlands’ cyber resilience practices, the interconnectedness of the financial system and the continued evolution of cyber threats calls for a continued focus and further enhancements. The FSB recommends that:

“Cyber incidents can pose systemic risks, disrupting critical financial services and eroding market confidence,” said Jane Magill, Chair of the Netherlands peer review. “Detailed examination of a jurisdiction’s approach provides benefits to all jurisdictions that are constantly looking to enhance their response to this risk.”

Notes to editors

Recognising the potential systemic risks posed by cyber incidents and the reliance on third-party providers, in 2023 the FSB published a Toolkit for enhancing third-party risk management and oversight, as well as recommendations to support harmonised incident reporting and information sharing among authorities. To build a practical understanding of implementation of these recommendations and other regulatory efforts to enhance cyber resilience, the FSB has conducted peer reviews of the Netherlands (published today) and Spain and their efforts to enhance the cyber resilience of their financial systems.’

FSB member jurisdictions have committed to undergo periodic peer reviews to evaluate their adherence to international financial standards. To fulfil this responsibility, the FSB has established a regular programme of country and thematic peer reviews of its member jurisdictions. As part of this commitment, the Netherlands volunteered to undergo a peer review in 2025. A schedule of country peer reviews, as well as all completed peer review reports, are available on the FSB website.

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

FSB Chair’s letter to G20 Leaders: November 2025

20 November 2025 | PDF full text (116 KB)

The FSB is operating in a world of considerable challenge, both in terms of seeking stronger economic growth and responding to a high pace of change in the world of finance.

This letter was submitted to G20 Leaders ahead of their Summit on 22-23 November 2025.

Acknowledging the challenging economic outlook, FSB Chair Andrew Bailey calls for global efforts to modernise and strengthen financial regulation without compromising financial stability and reaffirms the FSB’s commitment to support G20 member countries in these efforts.

The letter highlights the growing role of nonbank financial intermediaries, including private credit markets, the slow pace of progress in efforts to enhance cross-border payments and the evolution of the digital assets landscape. The letter outlines the work the FSB is doing to strengthen implementation of global regulatory reforms and to understand and respond to changes in the financial system, in particular, private credit markets and stablecoins.

Evolution of private credit markets and stablecoins warrant close monitoring, says FSB Chair

The FSB is operating in a world of considerable challenge, both in terms of seeking stronger economic growth and responding to a high pace of change in the world of finance.

Press enquiries:
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Ref: 21/2025

  • Acknowledging the challenging economic outlook, in his letter to G20 Leaders, FSB Chair, Andrew Bailey, calls for global efforts to modernise and strengthen financial regulation without compromising stability.
  • Letter highlights the growing role of nonbank financial intermediaries, including private credit markets and outlines steps the FSB will take to monitor this growing sector.
  • Letter underlines the urgency of improving cross-border payments and developing robust frameworks for stablecoins to ensure safe innovation and financial stability.

The Financial Stability Board (FSB) today published a letter from its Chair, Andrew Bailey, to G20 Leaders ahead of their Summit in Johannesburg on 22-23 November. In the letter, Andrew Bailey highlights the challenging economic outlook and the role financial authorities can play in supporting growth. The FSB’s interim report of its Implementation Monitoring Review identified significant gaps in the implementation of financial reforms. While the next phase of the FSB’s work will look deeper into where implementation was not achieved, Andrew Bailey stresses the importance of striking a balance between modernising financial regulation and ensuring its effectiveness in safeguarding the global financial system.

The letter highlights the increasing role of nonbank financial intermediaries in global financial markets, particularly in government bond markets and private credit markets, which have grown to an estimated US$2 trillion globally. The FSB remains committed to assessing the implications of these changes for the resilience of the financial system and ensuring that the evolution of nonbank finance does not compromise financial stability.

Andrew Bailey emphasises the need to accelerate progress on cross-border payments, warning that, despite some improvements, the current pace of change is insufficient to meet the ambitious goals set by the G20. The letter calls for accelerated momentum and continued attention to national policy barriers to achieve the objectives of the G20 Roadmap for Enhancing Cross-Border Payments.

New forms of payments and settlement are also emerging in what is a highly dynamic landscape. Digital assets, particularly stablecoins, are increasingly being used in payments, with implications for the financial system. Andrew Bailey calls on authorities to carefully consider how frameworks are designed to ensure they are effective, consistent, and supportive of safe innovation and notes that it will be equally important to consider how stablecoins can operate effectively and safely across borders. The FSB’s work programme for the year ahead will include a focus on stablecoins and other forms of payment.

The letter concludes by reaffirming the FSB’s commitment to supporting G20 member countries in addressing these challenges, maintaining financial stability, and ensuring that finance contributes to sustainable and inclusive economic growth.

Notes to editors

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

Strengthening global financial resilience: The FSB and G20’s shared mission

Article by FSB Chair Andrew Bailey in the magazine G20 South Africa: The 2025 Johannesburg Summit published by the G20 Research Centre at the University of Toronto.

Strengthening global financial resilience: The FSB and G20’s shared missionDownload

FSB Plenary sets out 2026 work plan

19 November 2025

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Ref: 20/2025

The Financial Stability Board (FSB), which plays a central role in safeguarding global financial stability, met on 18-19 November 2025 in Riyadh, Saudi Arabia. Members discussed vulnerabilities in the global financial system, challenges for emerging market and developing economies (EMDEs) and priorities for 2026, including additional work to support implementation. They also launched new initiatives related to modernising regulation and supervision, stablecoins, and nonbank financial intermediation (NBFI), and called for jurisdictional and regional action plans to promote improved cross-border payments.

Financial system vulnerabilities 

Members discussed the challenging global economic outlook. The Plenary acknowledged the vital role of financial stability in supporting sustained growth. In this context, members discussed the evolution of financial system vulnerabilities since their June meeting, focusing on key risks and challenges. They highlighted historically stretched asset valuations, particularly in AI-related securities, and the potential for sharp market corrections. The possibility for borrowing conditions to tighten, especially for riskier companies, was also a concern given the uncertain global economic outlook. Rising levels of government debt worldwide, driven by factors such as slower economic growth, higher spending, and aging populations, could adversely affect financial resilience. Members noted that nonbank entities are increasingly important participants in the markets for government debt, but their use of highly leveraged trading strategies could amplify market volatility and instability, potentially across borders, in the event of a rapid unwinding of positions. The group also discussed risks specific to EMDEs, emphasising the particular challenges they face and the importance of continuing to address these risks effectively.

Plenary members also discussed private credit markets. While acknowledging that private markets are improving access to credit, members noted their rapid growth, complexity, relative lack of transparency, and growing connections to the banking sector and the rest of the financial system, which require careful monitoring to assess potential risks to financial stability.

The Plenary called for continued close monitoring of the growing interlinkages between crypto-assets and stablecoins and the broader financial system. Stablecoins may improve payment speed and efficiency, but they raise a number of vulnerabilities, including run risk and regulatory challenges associated with multi-jurisdiction issuers of stablecoins , which require continuing attention.

Members also noted that operational disruptions at key financial institutions or technology providers can potentially cause significant system-wide impacts.

FSB work programme

The Plenary approved the FSB’s work programme for 2026, including key deliverables for the United States G20 Presidency.

A number of jurisdictions are considering or have initiated efforts to modernise financial regulation and supervision in their jurisdictions. The Plenary agreed that the FSB should examine these initiatives to determine where it can support alignment of approaches globally.   

Other areas of focus for 2026 include:

Crypto-assets and stablecoins

The FSB’s Thematic Peer Review of the FSB Global Regulatory Framework for Crypto-asset Activities, which was delivered to the G20 in October, highlighted the rapid growth of stablecoins and increasing interest from the traditional financial sector. The report also highlighted challenges related to regulatory fragmentation. Members emphasised the need for jurisdictions to align their regulatory frameworks, to prioritise financial stability, and to address anti-money laundering and countering the financing of terrorism concerns, as the crypto-asset sector continues to grow. In addition to vulnerabilities, members discussed the latest developments in stablecoins, including innovations, use cases, and policy responses, and considered work that the FSB should undertake on the financial stability implications of stablecoins, including laying the groundwork to address regulatory fragmentation and promote enhanced cooperation. Members noted the importance of coordination and collaboration across international organisations, standard-setting bodies and the Financial Action Task Force (FATF).

Implementation Monitoring Review

Plenary decided to move on to phase two of the strategic review of implementation led by Randal K. Quarles, the former Chair of the FSB. 

Cross-border payments 

The Plenary discussed progress on the G20 Roadmap for Enhancing Cross-Border Payments. The latest progress report, published in October, warned that the G20’s targets were unlikely to be met by the end-2027 deadline. Members called for jurisdictional and regional action plans to address specific challenges, including in EMDEs, and emphasised the need to continue to engage with the private sector to drive improvements. 

Nonbank financial intermediation (NBFI) 

The Plenary discussed the FSB’s work on enhancing the resilience of the NBFI sector. Members reviewed a report on vulnerabilities in government bond-backed repo markets and the links between the repo and government bond markets. The Plenary supported further work to promote implementation of the FSB’s recommendations on liquidity management by open-ended funds and on NBFI leverage. The latter includes work with the industry to enhance disclosure by nonbank entities to their prime broker counterparties. The Plenary noted the need for progress on addressing data gaps related to leveraged trading strategies in sovereign bond markets under the Nonbank Data Task Force.

Members also discussed options for work on private credit, including further assessment of vulnerabilities and interlinkages, as well as work on data gaps.

Resolution

The 2023 banking turmoil underscored the need to coordinate across different authorities to strengthen crisis preparedness. Members considered a proposal for a strategic review of the FSB’s crisis preparedness activities and emphasised the importance of ensuring the FSB is able to lead efforts in this area effectively. Continuing efforts to improve implementation monitoring of resolution standards in all sectors will form the basis of the FSB’s work on resolution in 2026. For the banking sector, the Plenary noted that funding in resolution remains a challenge for the effective implementation of the FSB’s resolution framework. This issue, alongside enhancing the effectiveness of the execution of cross-border bail-in, will also be addressed in 2026.

Insurance

The Plenary welcomed the FSB’s experience utilising the International Association of Insurance Supervisors’ Holistic Framework assessments instead of an annual identification of global systemically important insurers. Members approved the publication of the annual list of insurers subject to resolution planning standards and a consultation report on recovery and resolution planning requirements for insurers.

Conclusion

Governor Andrew Bailey, Chair of the FSB, commented: “This Plenary marks a significant step for the FSB. Our members have agreed to focus the work of the FSB to respond to changes in the pattern of financial stability vulnerabilities, the adoption of innovation, and to ensure a stable financial environment to facilitate economic growth. Our 2026 agenda of work is demanding, but we remain committed to closely scrutinising vulnerabilities in the market and resolutely following up to ensure the implementation of our recommendations across the globe.”

Notes to editors

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

Peer Review of Spain

18 November 2025 | PDF full text (568 KB)

Spanish authorities can build on work already done at national and European level to further strengthen the cyber resilience of the country’s financial system.

The growing digitalisation of Spain’s financial sector and its increasing reliance on services provided by third parties has heightened the sector’s exposure to operational risks and cyber threats.

The Spanish authorities have placed significant focus on enhancing cyber resilience of the financial sector. Banco de España (BdE) maintains robust risk-based supervisory oversight of the institutions it supervises, including a focus on cyber resilience. Spain was an early adopter of the Threat Intelligence Based Ethical Red teaming (TIBER) framework that provides structured red-team testing for banks. More recently, there has been a substantial effort across all financial sectors to prepare the industry for the increased expectations under the European Union (EU) Digital Operational Resilience Act (DORA).

Nevertheless, the evolving cyber risk landscape warrants continuing enhancements from Spanish authorities to address rising challenges. This peer review y recommends that Spanish authorities:

  • develop a comprehensive mapping of the cyber threat landscape that could provide the industry and authorities themselves with intelligence to inform decision-making;
  • leverage best practices to bring enhanced consistency and maturity to cyber resilience across agencies, for example through cross-sectoral working groups and information-sharing mechanisms under the oversight of the Spanish Macroprudential Authority;
  • develop a national analysis of existing registers of information to identify critical third-party providers in Spain, assess concentration risks and define a strategy to address domestically critical third parties;
  • establish a single national channel for incident reporting that automatically shares data with relevant authorities, as well as intergovernmental working groups, playbooks and drills to enhance crisis preparedness.

FSB recommends Spain further enhance cyber resilience of its financial sector to address rising challenges

Press enquiries:
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[email protected]
Ref: 19/2025

  • Peer review finds Spanish authorities have placed significant focus on enhancing cyber resilience of the financial sector and have good practices in place.
  • However, growing digitalisation of the financial sector and the evolving cyber risk landscape call for continuing improvements to address rising challenges.
  • The FSB recommends that Spanish authorities develop a comprehensive threat landscape, leverage best practices, and establish a national analysis of registers of information and a single national channel for incident reporting.

The Financial Stability Board (FSB) today published its second Peer Review of Spain, examining the country’s efforts to enhance cyber resilience in the financial sector and mitigate financial stability risks arising from operational incidents and cyber-attacks.

The review finds Spanish authorities have placed significant focus on enhancing the cyber resilience of the financial sector, including preparations to meet the enhanced expectations under the European Union Digital Operational Resilience Act (DORA). While Spain has implemented good practices, growing digitalisation of the financial sector and the evolving cyber risk landscape warrant on-going enhancements to address rising challenges.

The review recommends that Spanish authorities:

  • develop a comprehensive mapping of the cyber threat landscape that could provide the industry and authorities themselves with intelligence to inform decision-making;
  • leverage best practices to bring enhanced consistency and maturity to cyber resilience across agencies, for example through cross-sectoral working groups and information-sharing mechanisms under the oversight of the Spanish Macroprudential Authority;
  • develop a national analysis of existing registers of information to identify critical third-party providers in Spain, assess concentration risks and define a strategy to address domestically critical third parties;
  • establish a single national channel for incident reporting that automatically shares data with relevant authorities, as well as intergovernmental working groups, playbooks and drills to enhance crisis preparedness.

“Cyber incidents can pose systemic risks, disrupting critical financial services and eroding market confidence,” said Jane Magill, Executive Director of General Insurance and Banking at APRA and Chair of the Spain peer review. “Detailed examination of a jurisdiction’s approach provides benefits to all jurisdictions that are constantly looking to enhance their response to this risk.”

Notes to editors

Recognising the potential systemic risks posed by cyber incidents and the reliance on third-party providers, in 2023 the FSB published a Toolkit for enhancing third-party risk management and oversight, as well as recommendations to support harmonised incident reporting and information sharing among authorities. To build a practical understanding of implementation of these recommendations and other regulatory efforts to enhance cyber resilience, the FSB has conducted peer reviews of Spain (published today) and the Netherlands (forthcoming) and their efforts to enhance the cyber resilience of their financial systems.’

FSB member jurisdictions have committed to undergo periodic peer reviews to evaluate their adherence to international financial standards. To fulfil this responsibility, the FSB has established a regular programme of country and thematic peer reviews of its member jurisdictions. As part of this commitment, Spain volunteered to undergo a peer review in 2025. A schedule of country peer reviews, as well as all completed peer review reports, are available on the FSB website.

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

Practices Paper on the Operationalisation of Transfer Tools

17 November 2025 | PDF full text (2 MB)

Transfer tools enable the orderly resolution of failing banks, preserving critical functions without taxpayer loss.

Transfer tools are an important component of the FSB’s Key Attributes of Effective Resolution Regimes. They ensure the continuity of critical functions by transferring parts – or all – of a failed bank to a private-sector purchaser or a bridge entity, while ensuring that losses are absorbed by shareholders and creditors rather than taxpayers. The 2023 banking turmoil showed how these tools can provide authorities with more options in a crisis.

The paper sets out how authorities operationalise whole-bank and partial transfers, starting with the definition of the transfer perimeter. It outlines arrangements for operational continuity, such as transitional service agreements and management of third‑party contracts, and approaches to marketing the transfer perimeter under tight timelines and confidentiality. The paper explains how loss absorption, in line with the creditor hierarchy, is ensured via write-down and conversion or an estate claims process liquidating the residual entity.

The paper describes the establishment and operation of bridge entities and highlights key challenges for cross-border execution of transfer tools. The case studies included in this paper illustrate some of the operational topics and practices to enhance preparedness to deploy transfer tools effectively.

Transfer of parts of the failed bank and closure of the residual entity
Transfer of parts of the failed bank and closure of the residual entity

FSB Regional Consultative Group for Middle East and North Africa meets in Istanbul

13 November 2025

The Financial Stability Board (FSB) Regional Consultative Group for Middle East and North Africa (RCG MENA) met on 13 November in Istanbul, hosted by the Central Bank of the Republic of Türkiye.

The meeting, which brings together senior officials from central banks, financial authorities and regulatory bodies in the region, covered global and regional financial vulnerabilities, financial stability implications of debt sustainability, the role of nonbank financial intermediation in the region, as well as artificial intelligence (AI) and its use in finance.

Members also discussed the FSB’s ongoing work in 2025 and its priorities for 2026.