3.1 Introduction

This chapter provides a cross-sectoral analysis of the fit and proper requirements applicable to the different types of financial institutions which are the subject of EU financial regulation, such as credit institutions (banks), investment firms, pension funds and insurance undertakings (insurance companies). As will be seen, these requirements differ substantially across the different sectors. High standards, laid down in CRD IV and MiFID II, were not followed up upon by EU rules in other sectors. Against this backdrop, the question will be posed whether these differences can be adequately explained or whether more cross-sectoral harmonization is actually needed. This chapter concludes that fit and proper requirements in several sectors should be enhanced, taking into account the proportionality principle. This should lead to more cross-sectoral harmonization, following the example of the Netherlands. This chapter concludes with some recommendations for reform.