Amsterdam / Brussels – 17 June 2025
Today, Human Rights in Finance (EU) submitted an open letter to the Chairs of two key European supervisory bodies: ESMA (European Securities and Markets Authority) and the EDPB (European Data Protection Board). The letter raises the alarm over a growing oversight gap at the intersection of financial market regulation and data protection — with serious consequences for the rights of millions of European citizens.
Two interrelated systemic risks
Our open letter outlines two developments in the Netherlands with EU-wide implications:
- A material lack of disclosure in the Triodos Bank prospectus, which fails to mention regulatory enforcement history and legal risks that may affect the legitimacy of its financial instruments.
- The unlawful mass surveillance of payments via Transaction Monitoring Netherlands (TMNL), a joint initiative by five major Dutch banks. From 2021 to 2024, these banks processed over 6 billion payment records — including 2 billion involving sensitive personal data — without a lawful basis under the GDPR.
Both issues affect not just Dutch citizens, but also EU investors and bank customers across borders, given the presence of ING, ABN AMRO, Rabobank, Volksbank, and Triodos throughout the EU.
Triodos listing raises serious concerns
The new Triodos depository receipts (DRs) are scheduled to be listed on Euronext Amsterdam on Wednesday, 18 June. Yet despite detailed evidence and formal concerns submitted by HRIF.EU, Euronext has so far declined to pause the listing or conduct further due diligence.
Meanwhile, enforcement actions by the Dutch financial and data protection authorities are ongoing — including legal proceedings in which HRIF.EU represents the primary complainant.
Why European coordination is urgently needed
This case reveals a regulatory blind spot. Financial regulators and data protection authorities tend to act within their own silos — leaving cross-sector risks underexamined and underenforced. This is unacceptable in an era of integrated European markets and shared digital infrastructures.
HRIF.EU calls on ESMA and the EDPB to work together, act jointly, and protect fundamental rights and market integrity.
“We urge you to adopt a holistic supervisory perspective — one that safeguards the rights of European investors and bank customers, while promoting regulatory coherence, cross-sectoral oversight, and transparency across the Union.”
Read more and support us!
You can download the letter to ESMA and EDPB here and read this prior article on the deficiencies in the Triodos Listing.
And if after reading this article and our open letter you value the work we do on this matter, we also invite you to donate to Human Rights in Finance, using IBAN NL94 TRIO 0320 7857 85.