Blog | October 12, 2026
Why many banks and insurers in the Netherlands, Belgium and Luxembourg can't answer a simple question about their own IT
By Dr. Marc L. Brogle, Principal Advisor, Modernization & Transformation, DXC Technology
For banks and insurers in the Netherlands, Belgium and Luxembourg, application modernization starts with gaining a strong understanding of what applications are running the business and how.
Today, that understanding doesn't exist at most organizations. Ask a CIO at a Dutch bank, a Belgian insurer or a Luxembourg fund administrator which of their applications is most at risk of breaking first if they had to prove operational resilience to a regulator tomorrow, and they probably couldn't tell you. The reason is that the system that could go down first and fast may well have been built up over 30 or 40 years, changed by hundreds of different teams and documented unevenly, if at all.
Is there a way to answer such a question from a regulator? Yes, and until the work that needs to be done to get that answer is completed, these institutions need to step back from any thoughts they might have about leaping into application modernization. Long before leaders start to talk about moving workloads to the cloud, they need a current, fact-based picture of what the business' application estate actually does, how the pieces depend on each other and where the real risk sits.
Without that picture, modernization is a guess dressed up as a plan. And you don't want to be building out on a guess when it could mean you might miss taking the steps required to meet operational resilience obligations.
It's becoming increasingly urgent in this region for companies to have a scoped, sequenced view of the estate that tells them, application by application, whether something is safe to leave alone or needs urgent attention. The EU Digital Operational Resilience Act (DORA) has made this crucial, on top of the close supervision that Dutch, Belgian and Luxembourg institutions already know well. De Nederlandsche Bank (DNB), the Dutch Authority for the Financial Markets (AFM), the National Bank of Belgium (NBB), The Financial Services and Markets Authority (FSMA) and the Commission de Surveillance du Secteur Financier (CSSF) all expect banks, insurers and fund administrators to demonstrate operational resilience for the systems that matter most, including the legacy core platforms that process payments, manage policies or run fund positions.
Supervisory organizations are asking for evidence. And evidence about a mainframe application written in COBOL, or a fund administration platform built on a decades-old fourth-generation language, is hard to produce if the last person who fully understood it retired years ago.
This is where assessment-driven modernization earns its name. It means using structured analysis, code scanning, dependency mapping and business capability definition to build a defensible view of the estate before committing to any change. Done properly, this covers three things: what the application does from a business perspective, what it depends on technically, and what it would cost — in risk and in money — to leave it exactly as it is. Even if its risk of failure is considered tolerable, it potentially may be consuming a disproportionate share of your budget through licensing or specialist staffing costs.
In large modernization programs across financial services, this kind of assessment has uncovered realistic total cost of ownership savings in the tens to hundreds of millions of euros over a five- to seven-year horizon, simply by putting numbers against problems that had previously only been described in general terms.
The assessment itself reduces risk, independent of anything that happens afterward. Mapping dependencies and data flows across a business capability closes a real gap: institutions often discover that no single document anywhere describes how a given process, such as a cross-border fund transfer or a policy renewal, actually works end to end. Producing that documentation is valuable on its own, for audit, continuity planning and onboarding staff who did not grow up with the system.
None of this requires touching a live production environment. Modern approaches, including AI-assisted code analysis, can scan millions of lines of COBOL, Assembler or proprietary 4GL code and produce dependency maps and business capability descriptions in a fraction of the time a manual review would take, without any change to the running system.
That matters for risk-averse institutions that cannot afford an experiment in production, and it matters even more for Luxembourg entities where a fund administration error has direct client and regulatory consequences.
The practical starting point is narrower than most people expect. Rather than assessing an entire estate at once, the strongest results come from scoping the exercise around one regulated or cost-heavy domain: card processing, fund administration, policy administration or core ledger functions.
That keeps the effort manageable, produces a usable business case quickly and gives the institution a template it can repeat across the rest of the estate. DXC can support these assessments with proven tools and methodologies, drawing on more than 20 years of application modernization experience.
Once the application estate picture exists, the real decisions can start: what to rehost as is, what to rewrite, what to retire outright and how to move each of those pieces without disrupting the business that depends on them every day.
At DXC, we help banks across the Benelux modernize without compromising the stability of their mission-critical systems. With decades of experience managing and modernizing complex banking environments, we understand that successful transformation starts with a clear view of the existing IT landscape. Our pragmatic, risk-aware approach helps banks identify modernization priorities, unlock the value of their data, and integrate AI into business processes. This enables them to reduce complexity, respond faster to changing customer expectations and regulatory demands, and build a stronger foundation for future growth.
Dr. Marc L. Brogle is the Principal Advisor of Modernization & Transformation at DXC Technology. Connect with Marc on LinkedIn.
