Introduction
The Dutch Central Bank (De Nederlandsche Bank, DNB) regularly publishes a supervisory agenda for the various financial institutions under its supervision. For insurers, DNB has recently released the Supervision Calendar for Insurers 2026 (see link). This calendar outlines the sector-wide supervisory activities and related themes that DNB will focus on in 2026. In addition, each insurer will recieve an institution-specific supervision calendar with tailored activities via the DNB portal (Mijn DNB).
Below, we highlight the key supervisory activities for the Dutch insurance sector in the coming year.
Sector-wide supervisory activities for (re)insurers
In 2026, DNB will integrate two strategic themes into its supervision on insurers:
- Best estimate technical provisions; and
- Data management at insurers.
Best estimate: strengthening insight into insurance liabilities
Insurers must adequately determine their “best estimate liabilities”. The best estimate represents the most realistic possible assessment of future payouts and expenses arising from existing insurance policies, without any safety margin. This is a critical component in assessing an insurer’s solvency.
DNB will carry out a thematic review at a selection of insurers, excluding captives. The aim of this review is to assess how insurers ensure the accuracy of their best estimate calculations.
Data management at insurers
Insurers must have a robust data management framework, ensuring data is reliable, complete, up-to-date, and secure. Data management refers to the set of processes, systems, and measures that ensure data is reliable, complete, up to date, and secure.
DNB will request a thematic review from a selection of insurers, excluding captives. The objective is to gain sector-wide insights into the maturity of data management and to identify structural risks and bottlenecks within insurers.
Other key focus areas, external regulation and regular supervisory activities
In addition to the two strategic themes, DNB will address several ongoing supervisory topics and developments in 2026, including:
Cyber resilience
With the entry into force of the Digital Operational Resilience Act (DORA), managing risks related to information security, cybersecurity, and outsourcing remains a priority for DNB. In 2026, supervision will focus on, inter alia,: (i) managing IT/cyber risks and risks associated with outsourced ICT services; (ii) obtaining and maintaining up-to-date information on ICT concentration risk in outsourcing chains through information registers; and (iii) improving insight into signals from threat analyses, incident reports, and the SBA Cyber Resilience 2026 analysis. DNB will conduct risk-assessment interviews and deep dives with selected insurers and organise seminars and roundtables.
Geopolitical risks
DNB will continue its 2025 research into geopolitical risks, analyzing how geopolitical developments may impact insurers. DNB will share insights, host a roundtable with insurers, and develop a plan for ongoing monitoring and knowledge sharing.
AI in insurance
DNB will continue monitoring the use of AI applications in the sector through the annual sector-wide survey (SBA-NFR), expected in Q1 2026. Based on the results, DNB will conduct risk-based, in-depth reviews in Q2 2026 at selected insurers, focusing on AI usage, policies, and risk management.
Key function holders
Under Solvency II governance, key functions play a critical role. DNB will carry out an exploratory thematic review at so-called i1 institutions (larger/complex insurers, including Basics) to gain insight into the actual implementation and functioning of key roles and how proportionality applies.
Future of Pensions Act
The Future of Pensions Act (Wet toekomst pensioenen) came into effect on 1 July 2023. Insurers have until 1 January 2028, to comply. In 2026, DNB will continue monitoring the transition and implementation of new pension rules through individual and sector-wide reviews, focusing on buy-outs, risk appetite, and investment strategies.
Solvency II Review – Impact Assessment YE2025
As in previous years, DNB will conduct a survey on the impact of legislative changes resulting from the Solvency II review. This includes: (i) a quantitative survey to map the financial impact on the sector and individual insurers (reference date: 31 December 2025); and (ii) a qualitative survey. The deadline for this survey is 29 May 2026. DNB stimulates all insurers to voluntarily participate in this survey.
Resolution planning
DNB will continue its annual information request on resolution planning, focusing in 2026 on operationalising resolution plans through playbooks. At the same time, DNB is developing a framework for assessing resolvability to monitor insurers’ progress.
Private assets and loan-level mortgages survey
DNB will request data on private assets and Dutch mortgages held, given the growing investment in private assets. This additional data request aims to better assess potential financial stability implications.
Integrity reporting
DNB will conduct a regular sector-wide survey on integrity risks and their management within selected insurers.
Contact
If you have any questions about this or other topics related to financial regulation, please contact our Financial Regulatory Team.
