DNB issues group DNOs to the acquiring company and its group companies together. The merit of a group DNO is that there is no need for the group companies of the acquiring institution to apply for separate DNOs. Generally speaking, a shift within the group of shares in an existing shareholding, does not need a new DNO application.
Group DNOs can only be issued to the group of which the acquiring company is part. Group DNOs are not possible for the group of which the target company is part at the time of the application. If via the target company, a qualifying holding in another company having its registered office in the Netherlands is acquired, a separate DNO application for the other company must be filed with DNB. If the other target company has its registered office outside the Netherlands, but within the European Economic Community (EEC), the application for a DNO for the other target company must be filed with the supervisory authorities of the relevant country.
DNO by request
A group DNO is only issued by specific request and only to an economic entity whose legal persons and companies are organisationally connected under a single, central managing entity. Natural persons are not part of a group and are required to file their own individual DNO applications. The holders of a group DNO are required to notify changes in the shareholder structure of the target company to DNB. Such changes may give DNB ground to perform a supplementary assessment.
A shareholding in a bank
We strongly advise against applying for a group DNO for the acquisition of a shareholding in a bank, as future shifts within the group are very likely to need a new DNO application procedure. The ECB's policy is leading here.