Gerd-Jan van Wiggen: When the ATM falls silent

December 16, 2025

_{This column was originally written in Dutch. This is an English translation.}

By Gerd-Jan van Wiggen, Partner at Probability & Partners

Many people in the Netherlands have now received the booklet on how to prepare for an emergency. This prompted us to organise a lunch discussion on personal operational resilience. A brief survey showed that most people do have a small supply of food and drink at home. Candles and matches also score well. However, having some cash at home turned out to be an area for improvement.

I experienced first-hand how disruptions can occur during a holiday in the Médoc a few years ago. A lightning strike on a transmission mast temporarily disrupted payment transactions in part of the region. As a result, card machines in shops were not working and the only ATM in the village that did not require a direct connection was stormed by everyone. Unfortunately, the person in front of me turned out to have taken the last notes out of the machine. However, I still had to do some shopping, so I decided to take the car to a neighbouring village. This turned out to be unsuccessful, as I didn't have enough petrol. Refuelling along the way was also impossible due to the disruption. Fearing I would be stranded somewhere, I drove back to our cottage. In the end, I reclaimed my daughters' pocket money so I could buy some food and drink. They did not yet have bank accounts and had their assets in their pockets in the form of shiny euro coins.

After a year of unprecedented geopolitical and economic developments, it seems to have sunk in that a new wind is blowing and we must prepare for all kinds of scenarios in which such a lightning strike will occur. I believe 2026 will be the year of the transition from a multilateral to a multipolar world. Here are a few themes to keep an eye on.

Deregulation

In the US, we have been seeing legislation and regulations being scrapped or relaxed for various parties for some time now, including in the financial sector. This seems to be putting various European parties at a competitive disadvantage. With the various types of Omnibus legislation, the EU hopes, among other things, to achieve sufficient simplification to address this disadvantage.

Last week, the ECB published proposals based on the work of the High-Level Task Force on Simplification. Since March, this task force has been active in formulating recommendations to reduce the complexity of prudential legislation and regulations. In doing so, this group aims to increase the competitiveness of European banks. Notable elements include the simplification of the risk-weighted assets framework and the leverage ratio framework, and a substantially simpler regime for smaller banks. Attention is also drawn to the completion of the Savings & Investment Union.

Following the 2008 financial crisis, prudential legislation and regulations expanded enormously. A large number of points, such as the liquidity framework, were rightly introduced. An evaluation of the complexity of the whole is a positive development. My main concern here is the speed with which things are ultimately implemented. Decision-making within the EU can take longer than desired due to various conflicting interests. As the world becomes more multipolar, there is an increased risk that the EU will lag behind other blocs due to a lack of decisiveness.

Financial stability

Geopolitical and macro-financial developments could ultimately have a negative impact on bank and non-bank lending. The ECB recognises this in its supervisory themes for the next three years. Banks are currently in a good position in terms of capital and liquidity, and asset quality is also relatively good at present. Nevertheless, vigilance remains important due to various developments.

One example of this is the increased unpredictability of policy choices. The volatility of US trade tariffs has already proved to be a headache this year in terms of economic expectations, and changes in interest rate policy may also have far-reaching consequences worldwide. And although the European economy has so far proved more robust than expected, we are seeing all kinds of problems emerging in some sectors, such as the automotive industry, which could put pressure on the broader economy in the coming year and thus on the quality of loan portfolios.

Stablecoins are a new category of assets that is rapidly emerging. Their processing speed and low costs make them particularly interesting as an alternative to existing payment services in international payments. These advantages could lead to their rapid acceptance as a means of payment. Whether stablecoins will ultimately be stable – as their name suggests – remains to be seen in practice. Panic selling can also have an impact on the underlying assets, which come from the traditional financial system. As a result, coin-related issues can spread to the wider financial world.

Operational resilience

Operational resilience has been a familiar concept in the IT domain for years, and preparing for and averting cyber attacks is part of everyday work. In recent years, we have already seen the scope of operational resilience increase, including towards suppliers and their subcontractors. Many initiatives in this area focus on a financial institution's own sphere of influence. The focus on disruptions in public infrastructure and the environment will only increase in the coming period. How do you prepare your organisation for a scenario such as a failure caused by a malicious actor opening a lock or a failure of communication means?

Your subsidiaries are not always there to help you out. The financial sector, like ourselves, must become resilient to such lightning strikes. Developing scenarios and testing alternative options are the best way to respond to the changes that are currently taking place.