Masterclass – Section 20 Wtt 2018: Incident Reporting in Practice

For many institutions, reporting an incident to DNB can feel like putting your head on the chopping block. A report may trigger an investigation, and DNB’s expectations do not always align with what is practically achievable. This often leads to friction with the supervisory authority or unrest within the organisation.

But what exactly qualifies as an incident and who makes that determination? What were the legislator’s original intentions, and how does DNB interpret its scope today? One thing is certain: failing to report can result in enforcement action. In that sense, Section 20 of the Wtt 2018 remains a particularly tricky provision. Whatever you do, it can sometimes feel like a lose‑lose situation.

In the first part of this masterclass, we will examine the origins of the rule and how its interpretation has evolved over time. In the second part, we will explore recent cases and the current supervisory approach.

The purpose of the session is to provide practical tools and a robust decision‑making framework—so that you can report with confidence when appropriate, or with equal confidence decide not to.