Credit Risk Manager

KOS International Talent Group; Amsterdam; On-site; EUR 150,000 - 190,000; Full time

Job summary

KOS International Talent Group seeks a senior risk leader to act as the statutory director for a Dutch entity and to drive day‑to‑day risk policymaking. You will obtain and maintain AFM approvals for risk activities, lead or support a consumer‑credit licence application, and develop the risk appetite, policies and governance framework presented to the board.

This role requires strong regulatory expertise, practical underwriting insight and the ability to translate complex rules into clear,

Qualifications

• Experience leading consumer-credit risk and governance functions.
• Proven track record with AFM and regulatory approvals.
• Ability to translate complex regulations into practical policies.
• Experience in risk assessment and governance reporting.
• Experience engaging with board-level stakeholders.

Responsibilities

• Serve as statutory director and day-to-day policymaker for risk.
• Lead or support AFM licence applications for consumer credit.
• Develop risk appetite, policies, and governance framework presented to the board.
• Define customer eligibility, credit limits, and decline criteria.
• Develop credit-scoring and decisioning strategies.
• Monitor risk metrics and portfolio outcomes.
• Provide training on credit-risk requirements.
• Own the credit-risk relationship with the AFM.

Skills

Credit risk

Regulatory knowledge

Policy development

Board communication

Analytical skills

Regulatory drafting

Stakeholder management

Independent work

Job description

• Serve as a statutory director of the Dutch entity and as its day-to-day policymaker for risk.
• Obtain and maintain AFM approval as a day-to-day policymaker before appointment.
• Lead or support the entity's application to the AFM for a licence to offer consumer credit.
• Develop and maintain the entity's consumer-credit risk appetite, policies and governance framework, and present them to the board for approval.
• Define customer eligibility, credit limits, loan amounts, repayment terms and decline criteria.
• Design controls for repeat borrowing, concurrent borrowing, the stacking of multiple small obligations, and credit-limit increases.
• Develop credit-scoring, underwriting and decisioning strategies.
• Review and approve material changes to credit policies and decisioning models.
• Develop management information and reporting for the consumer-credit portfolio.
• Monitor approval rates, utilisation, arrears, defaults, losses, recoveries and customer outcomes.

Governance and oversight

• Act as the principal subject-matter expert for consumer-credit risk and as the board-level owner of the risk-management function.
• Design and maintain risk-management, compliance and internal-audit arrangements proportionate to the entity, with sufficient independence from the commercial lines.
• Establish clear ownership, delegated authorities and escalation routes for credit-risk decisions.
• Maintain the entity's credit-risk policies, procedures and mandates, the incident-handling procedure and the notification obligations owed to the AFM.
• Work with Compliance Monitoring and Internal Audit to test the effectiveness of credit controls.
• Support complaints handling and the entity's Kifid arrangements as they relate to credit decisions, affordability and arrears.
• Support Risk Committee, management board and supervisory board discussions relating to consumer lending.
• Provide training on credit-risk requirements and responsible lending, and support the oath obligations applying to customer-facing and risk-relevant staff.
• Own the credit-risk relationship with the AFM and support the entity's wider supervisory dialogue.
• Previous experience of leading or materially supporting a consumer-credit licence application to the AFM, or a closely comparable authorisation application to another EEA financial regulator.
• Strong knowledge of Dutch consumer-credit regulation: the credit provisions of the Wft and BGfo, Book 7 Title 2A of the Dutch Civil Code, and the AFM's supervisory approach and guidance.
• Working knowledge of CCD2 and its Dutch implementation, and of what it changes for short-term credit, BNPL and deferred payment.
• Experience working for a regulated lender, bank, fintech, payment institution, electronic money institution or BNPL provider.
• Practical experience of consumer-credit underwriting and affordability assessment in the Dutch or a comparable European market, including the credit register and Nibud-based lending norms.
• Experience developing credit-risk policies, strategies and governance arrangements.
• Experience monitoring a consumer-credit portfolio and producing credit-risk management information.
• Experience working with senior management, regulators, external advisers and cross-functional teams.
• Strong understanding of the Dutch duty of care and the AFM's expectations on embedding the customer's interest, with the judgement to apply them absent a single codified outcomes duty.

Skills and competencies

• Strong analytical and quantitative skills.
• Excellent understanding of credit-risk principles and responsible lending.
• Ability to translate regulatory requirements into practical policies and controls, including where the final text of the requirement is not yet settled.
• Strong written communication and regulatory drafting skills.
• Sound judgement and the ability to challenge commercial proposals constructively, including at board level and against the group.
• Ability to explain complex credit-risk matters clearly to senior stakeholders, supervisors and non-specialists.
• Strong project-management and organisational skills.
• Ability to work independently and to manage several regulatory and operational priorities simultaneously.
• High standards of integrity, accountability and attention to detail, commensurate with a regulator-approved board appointment.