Banking sector develops plans for Disciplinary Law 2.0 following termination by the Foundation for Banking Ethics Enforcement
25 september 2026
The Dutch Banking Association (NVB) has taken note of the decision by the Foundation for Banking Ethics Enforcement (FBEE) to cease the implementation of the banking disciplinary framework. Earlier, the FBEE was formally notified by NVB of not meeting contractual obligations after it refused to allow disciplinary hearings to take place. The NVB welcomes the resumption of the hearings.
The termination does not come as a surprise to the NVB. It had already been announced informally in June. Therefore, in consultation with its members, the NVB began developing a newly designed Disciplinary Law 2.0 framework this summer. Banks attach great importance to the proper implementation of the statutory requirement to provide a disciplinary framework for bank employees. The NVB will further develop these plans in the coming period and will establish a new disciplinary framework as quickly as possible. An orderly transition is essential, with due regard for the position of reporting parties, the bank employees concerned and ongoing cases.
Modernisation of the disciplinary framework
Modernisation of the banking disciplinary framework is necessary to make the system clearer, more rigorous, and better equipped for the future. It should more clearly define that the disciplinary framework concerns individually culpable conduct by bank employees, rather than general bank policy or broader societal debates about the sector. These matters are already subject to extensive oversight by the regular supervisory authorities. A uniform reporting policy is also needed, so that banks handle potential disciplinary cases in a consistent manner. In this way, the disciplinary framework can continue to fulfil its intended purpose: promoting professional and ethical conduct among employees in the banking sector.
Background
Over the past two years, the NVB and the FBEE have held intensive discussions on the recalibration of the banking disciplinary framework. One of the reasons for this process was the 2024 evaluation conducted by the University of Groningen: Evaluation of the Disciplinary Framework for Bank Employees. Based on that evaluation, work was undertaken on a revised disciplinary code and a harmonised reporting policy for banks. The FBEE has informed the NVB that there is insufficient support within the foundation for the proposed revised code.