On 17 April 2025, the Dutch Minister of Finance published a letter outlining potential changes to the existing Dutch remuneration rules for the financial sector. In this publication, we highlight the main takeaways from this letter.
- The letter indicates that the Dutch government is considering ways to allow for more flexible compensation arrangements for so-called "specialised personnel," including providing compensation through shares.
- In the letter, the Dutch Minister of Finance acknowledges that the Dutch remuneration rules for financial institutions are stricter than the rest of Europe and more specifically that the Dutch bonus cap makes it challenging for financial institutions to attract and retain specialised personnel, particularly in areas such as IT, compliance, and risk management. These professionals are in demand not only by financial institutions but also by other European (BigTech) companies. The letter mentions that financial institutions must compete for the same scarce talent with companies that are not subject to the same remuneration rules.
- The letter further states that many financial institutions have increased fixed salaries to remain as competitive as possible. This poses particular challenges for innovative companies like FinTechs, which find it more difficult to sustain structurally high fixed costs. These companies would prefer to compensate their employees with shares, especially in their early stages, to reduce wage costs. However, the current remuneration rules make this more difficult, according to the letter.
- While more flexible remuneration rules for specialised personnel are considered, the letter makes clear that there will be no changes to the remuneration rules for management board members of financial institutions.
The letter does not provide concrete timelines regarding the above potential changes, nor does it define the term "specialised personnel." We will closely monitor any developments in this regard.
The letter can be consulted here (in Dutch only).
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Should you have any questions or wish to discuss how these potential changes might affect your compensation strategy, please contact us.
