Licensing and intellectual property
Payment Institution and EMI Licence in the Netherlands
Your business model mapped to a licence or an exemption, the applicant company and its policymakers in place, and a complete file with DNB, prepared for the statutory procedure.
- Licensing authority: De Nederlandsche Bank (DNB)
- Decision: three months from a complete file
- Initial capital: EUR 20,000 to EUR 125,000 for a PI, EUR 350,000 for an EMI
- DNB application fee 2026: EUR 10,400, not refunded on refusal
DNB licensing for payment and e-money businesses
We prepare payment and e-money businesses, often founded abroad, to operate from the Netherlands. Anyone with a seat in the Netherlands needs a licence from De Nederlandsche Bank (DNB), the Dutch central bank, to provide payment services (art. 2:3a(1) Wft) or issue electronic money (art. 2:10a(1)).
This page covers both licences, payment institution (PI) and electronic money institution (EMI), and the routes needing no licence. Crypto-asset services fall under MiCA at the AFM: see our crypto licence service.
What's included
Seven pieces of work, from scoping to after the grant.
Scoping
Your services against the PSD2 Annex (6 money remittance, 7 payment initiation, 8 account information; 1 to 5 by number), exclusions, exemptions, PI or EMI, and capital class.
The applicant company
A Dutch BV applies; an EMI licence goes only to a legal person (art. 2:10b(1) Wft). An existing BV taken over instead changes hands by notarial share transfer: see shelf companies in the Netherlands.
Announcing the file
Contact with DNB's Expert Centre on Market Access to announce the application and ask about processing time; an InnovationHub question where the model is new.
The application file
Evidence for every condition of art. 2:3b(1) or 2:10b(1) Wft, a fit-and-proper file per policymaker, and a declaration of no-objection application per qualifying holder.
Filing and the procedure
Submission, payment of the state charges, and answers to DNB's requests for missing information, so DNB does not cease considering the file.
Exempt routes and after the grant
Small-provider, small-EMI, limited-network and telecom-billing notifications; after the grant, where engaged, agent and passport notifications and licence amendments.
Where our work stops
DNB decides; no outcome or date is guaranteed. We do not supply a director or policymaker, the BV's address with this work, the capital or the safeguarding (Wtt 2018 art. 1 limbs a and b, art. 3(4)(a)). A DNB trust licence is a separate regime: see our trust office licence service.
Licence, exemption or no licence: the four routes
The route follows your services and volumes; the law sets each one, and the choice is made in a conversation.
Payment institution licence
Payment services from a Dutch seat. Initial capital EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only, EUR 125,000 for any of services 1 to 5, none for account information only (art. 48(1) Bpr).
Electronic money institution licence
Issuing e-money, by a legal person only. Initial capital EUR 350,000 (art. 48(1)(n) Bpr), and e-money funds safeguarded at the latest five business days after issue (art. 40b(1) Bpr).
The two small-firm exemptions
Services 1 to 5 in the Netherlands only, average below EUR 3 million a month, notified through the Digital Supervision Portal (DNB exemption page). Small EMI: EUR 150 per instrument, EUR 5,000,000 outstanding, no agents. No regular DNB supervision; art. 26e to 26h Bpr, the AFM conduct rules (art. 4:25d Wft) and the Wwft still apply.
The exclusions of art. 1:5a(2) Wft
The limited network (letter k), notified once twelve months of transactions reach EUR 1 million; telecom billing up to EUR 50 a transaction and EUR 300 a subscriber a month (letter l) (DNB exclusions page). Also excluded: commercial agents, cash-only payments, technical providers, intra-group payments, independent ATMs.
How the licence application works
Eight steps, with the official timing where one exists.
Scoping
Your PSD2 services, exclusions and exemptions, PI or EMI, capital class and safeguarding method; an InnovationHub question if the model is new. Timing: no official time.
The applicant BV
Notarial deed (art. 2:175 BW), then KVK registration filed within one week (art. 20 Hrw 2007), EUR 85.15 in 2026; see the detailed Dutch BV page. You appoint the two day-to-day policymakers. Timing: one week to register.
Capital and safeguarding
Initial capital at the art. 48 Bpr level; a designated account at a Dutch-seated bank, or a separate account, safe assets, insurance or a guarantee. Timing: no official time.
Announce the file
Contact DNB's Expert Centre on Market Access to announce the application and ask about processing time. Timing: no official time.
Assemble the file
Evidence per licence condition, fit-and-proper material per policymaker, and a declaration of no-objection application per qualifying holder, filed alongside. Timing: no official time.
Submit and pay
EUR 10,400, plus EUR 2,900 and EUR 1,600 per screened person and EUR 7,300 per declaration of no-objection, charged whatever the outcome. Timing: the clock starts on a complete file.
DNB review
Three months from a complete file (art. 2:3b(7), 2:10b(4) Wft). Missing information pauses the clock, and an unsupplemented file may be dropped within four weeks (DNB timeline factsheet). Timing: three months by statute; DNB says it tends to be longer.
Decision and the register
Operations start only after the licence is issued or the exempt registration is entered. The DNB public register is updated every business day at 06:00. Timing: no start before the licence.
Set by statute or DNBDNB practice indicationNo published time
- File submitted, charges paidThe applicantThe clock starts only on a complete file
- Is the file complete?DNBNo: DNB asks and the clock pauses Not supplemented: consideration may cease within four weeks
- DNB reviewDNBThree months from a complete file (art. 2:3b(7), 2:10b(4) Wft) Not the general thirteen-week period (art. 2:3b(8) Wft) DNB: total processing time tends to be longer than three months
- Decision and register entryDNBNo end date published
- Start of operationsThe licence holderOnly after the licence is issued
Licence, exemption or no licence at all?
Tell us your planned services and volumes; we settle the route, capital class and safeguarding before drafting.
What DNB will ask you for
What the licence conditions require the file to prove; the full list is set by order in council and DNB's form (art. 2:3b(6) Wft).
- Your business model mapped to the PSD2 services, with evidence for any exclusion or exemption
- Proof that part of the business is carried on in the Netherlands (art. 2:3b(2), 2:10b(2))
- A group and control structure transparent enough for supervision (art. 3:16)
- The operational set-up for sound operational management (art. 3:17)
- An integrity policy (art. 3:10), Wwft due diligence and FIU-NL reporting
- The safeguarding arrangement: designated account (art. 3:29aa) or art. 40a or 40b Bpr
- The two day-to-day policymakers and how they work from the Netherlands (art. 3:15(2))
- Fitness (art. 3:8) and propriety (art. 3:9) material for every policymaker
- Proof of initial capital at the art. 48 Bpr level and a solvency plan (art. 3:57)
- A declaration of no-objection application for every qualifying holder (art. 3:95)
Requirements, capital and DNB charges in 2026
Each figure is a fact of law, with its code or article in the Financial Supervision Act (Wft) or the instrument named; our fee is on request.
Payment institution and EMI licence requirements, initial capital and DNB charges in 2026, from the Wft, the Bpr, the charges regulation and DNB; checked in October 2026. PSD3 and the Payment Services Regulation: agreed politically on 27 November 2025, not adopted; PSD2 as transposed in the Wft governs a file submitted now.
| Item | Payment institution | Electronic money institution | Source |
|---|---|---|---|
| Licence | DNB licence for anyone with a seat in the Netherlands providing payment services | DNB licence to issue electronic money; banks carved out | Art. 2:3a(1), 2:10a(1) and (2) Wft |
| Who applies | A Dutch company; a seat outside the EU is barred; part of the business in the Netherlands | A legal person only; the same seat and Netherlands-business rules | Art. 2:3f(1)(a), 2:3b(2), 2:10b(1) and (2) Wft |
| Initial capital | EUR 20,000 remittance only · EUR 50,000 initiation only · EUR 125,000 services 1 to 5 · none for account information only | EUR 350,000 | Art. 48(1)(j), (k), (l), (n) Bpr; art. 2:3b(5) Wft |
| Management | At least two natural persons determine day-to-day policy, working from the Netherlands | Same | Art. 3:15(1) and (2) Wft |
| Safeguarding | Funds from payment service users; not for a PI providing only services 7 and 8 | Also e-money funds, at the latest five business days after issue | Art. 3:29a, 3:29aa(2) Wft; art. 40a, 40b(1) Bpr |
| Decision period | Three months from a complete file; the thirteen-week rule disapplied; DNB: tends to be longer | Same | Art. 2:3b(7) and (8), 2:10b(4) Wft; DNB |
| Application fee 2026 | EUR 10,400 (Wft.D1.01), not refunded on refusal or withdrawal | EUR 10,400 (Wft.D1.05), same | BWBR0041647; DNB, fees charged upon application |
| Per person and per holder | Suitability EUR 2,900 (Wft.D7.01) and propriety EUR 1,600 (Wft.D7.02) per screened person; EUR 7,300 per declaration of no-objection (Wft.D4.07) | Same tests; EUR 7,300 (Wft.D4.08) | BWBR0041647; art. 3:95(1)(h) and (i) Wft |
| Small-firm exemption | Services 1 to 5, Netherlands only, average EUR 3 million a month | EUR 150 per instrument, EUR 5,000,000 outstanding, no agents | DNB exemption pages |
| Starting and keeping it | Start only after the licence; withdrawal if unused for twelve months or stopped for more than six months | Same; European passport after notifying the home supervisor | DNB; art. 1:104(1)(e) and (f) Wft |
Problems we solve
Five things payment founders are told, and what the rules say.
- "The capital must sit in a Dutch bank."
The Dutch-bank rule belongs to the safeguarding account (art. 3:29aa(2) Wft), not the capital. Whether a bank opens that account is its own decision; we prepare the file and the art. 40a Bpr alternatives.
- "The directors must live here, and we were offered one."
Two natural persons determine day-to-day policy and work from the Netherlands (art. 3:15 Wft); the statute does not say "resident". You appoint them. A non-EU founder who moves needs a permit, a separate question: see the Netherlands start-up residence permit.
- "Our parent company is in the US."
A company seated outside the EU may not carry on payment business in the Netherlands (art. 2:3f(1)(a) Wft). The applicant is a Dutch company; an EMI must be a legal person.
- "We are exempt now, but growing."
An exempt payment service provider loses the exemption by operation of law once it stops meeting the conditions; an outgrown small EMI must stop operating as one unless licensed. DNB advises preparing the licence application well ahead.
- "We could buy a licensed company instead."
A qualifying holding needs DNB's declaration of no-objection first (art. 3:95(1)(h) and (i) Wft), EUR 7,300 per declaration: a DNB procedure of its own. We do not sell, find or match licensed companies.
Are your policymakers and your safeguarding in place?
Send your policymakers, qualifying holders and safeguarding plan; we reply with the file each one needs.
Why work with us
We map the model to the PSD2 services and test the exclusions first, settle the capital class and safeguarding before drafting, build a fit-and-proper file per policymaker and a no-objection file per holder, and answer DNB's requests.
Ilse Brouwer, tax, VAT and licensing lead, Amsterdam; Dutch, English and French. She assembles AFM and DNB licence files.
Related services
- The operating accountA separate service from the safeguarding account.
- Who may run your companyWhy nobody may supply your directors without a DNB trust licence.
- Your payment brandProtecting the name you will trade under.
Frequently Asked Questions
Is the DNB decision period 13 weeks or three months, and why does it usually take longer?
Three months. DNB decides within three months of receiving a complete application (art. 2:3b(7) and 2:10b(4) Wft), and the general thirteen-week period is expressly disapplied. The clock starts only on a complete file and pauses while information is missing, so DNB says the total tends to be longer. Operations start only after the licence is issued.
Do the directors of a Dutch payment institution have to live in the Netherlands, and can you provide them?
The Wft requires at least two natural persons who determine the day-to-day policy and carry out that work from the Netherlands (art. 3:15); it does not say resident. You appoint them. We do not supply directors or policymakers: acting as director for a client is a trust service under art. 1 Wtt 2018 and needs a DNB licence.
Does the capital have to be deposited at a Dutch bank?
No. Neither art. 3:53 Wft nor art. 48 Bpr requires the initial capital to be paid in at a Dutch bank. The Dutch-bank rule belongs to safeguarding: a designated account for client funds is held at a bank with a seat in the Netherlands (art. 3:29aa(2) Wft), unless an alternative under art. 40a Bpr is used.
Can a company from outside the EU hold a Dutch payment institution licence?
Not directly. A company with its seat in a state outside the EU may not carry on the business of a payment service provider in the Netherlands (art. 2:3f(1)(a) Wft). The applicant is a Dutch company that will carry on at least part of its business in the Netherlands, and an EMI licence goes only to a legal person.
Is the DNB application fee refunded if the licence is refused?
No. DNB charges the application fee whether it grants or refuses the application, and also when the applicant withdraws it. In 2026 the fee is EUR 10,400 for a payment institution (code Wft.D1.01) and EUR 10,400 for an electronic money institution (Wft.D1.05), under the one-off supervision charges regulation.
How much does a payment institution licence cost in the Netherlands?
On the state side: EUR 10,400 for the application, EUR 2,900 for the suitability test and EUR 1,600 for the propriety test per screened person, and EUR 7,300 per declaration of no-objection, all charged whatever the outcome. DNB also charges an annual supervision fee. The initial capital is a standing requirement, not a fee. Our fee is on request.
What are the requirements for a payment institution licence in the Netherlands?
Fit and proper policymakers, sound and ethical operation, two day-to-day policymakers working from the Netherlands, a transparent control structure, sound operational management, safeguarding, minimum own funds and solvency (art. 2:3b(1) Wft). The applicant also shows part of its business in the Netherlands, and every qualifying holder applies for a declaration of no-objection.
How much capital does a Dutch payment institution or EMI need?
It follows the services (art. 48(1) Bpr): EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only, EUR 125,000 for any of services 1 to 5 of the PSD2 Annex, and EUR 350,000 for an electronic money institution. An account-information-only firm has no initial capital figure (art. 2:3b(5) Wft).
What is the difference between a payment institution and an EMI licence?
An EMI also issues electronic money, must be a legal person and needs EUR 350,000 of initial capital, against EUR 20,000 to EUR 125,000 for a payment institution. It safeguards e-money funds at the latest five business days after issue. Both pay a EUR 10,400 application fee in 2026 and face the same three-month decision period.
Is there an exemption for small payment service providers or small EMIs?
Yes, two. A small provider offers services 1 to 5 in the Netherlands only, averaging at most EUR 3 million a month over twelve months. A small EMI stays within EUR 150 per instrument and EUR 5,000,000 outstanding, with no agents. Neither is under regular DNB supervision, and a provider that stops meeting the conditions loses it at once.
What is the limited network exclusion, and when must I notify DNB?
Art. 1:5a(2)(k) Wft excludes instruments usable only at the issuer's premises, within a limited network of providers with a direct commercial agreement with the issuer, or for a very limited range of goods or services. DNB must be notified once transactions over the past twelve months reach EUR 1 million; complete notifications enter the DNB and EBA registers.
Can I buy a company that already holds a Dutch PI or EMI licence?
Buying one is a DNB procedure, not a shortcut. Holding, acquiring or increasing a qualifying holding in a payment institution or an electronic money institution requires DNB's declaration of no-objection first (art. 3:95(1)(h) and (i) Wft), charged at EUR 7,300 per declaration in 2026. We do not sell, find or match licensed companies.
How must a payment institution safeguard client money?
Either on a designated account at a bank with a seat in the Netherlands, held for third parties, where any shortfall is topped up at once (art. 3:29aa Wft), or by the methods of art. 40a Bpr: no commingling, then a separate account, safe and liquid low-risk assets, an insurance policy or a guarantee from outside the group.
How do I check whether a provider is licensed by De Nederlandsche Bank?
De Nederlandsche Bank, the Dutch central bank, is not DNB Bank of Norway. Its public register lists payment service providers and electronic money institutions, licensed and exempt. DNB updates it every business day at 06:00, and it can be downloaded as a CSV file. An exempt provider must also state that it is not under regular supervision.
What will PSD3 and the Payment Services Regulation change?
Nothing yet. The Commission proposed the Payment Services Regulation and the PSD2 amendment in June 2023 (COM(2023) 367), and the Council and the Parliament reached a provisional political agreement on 27 November 2025, with technical work to follow before final adoption. PSD2 as transposed in the Wft governs an application filed now.
Request a payment licence plan
Tell us your services, planned volumes and who will run the business; we reply with the route, the capital class and the file. Pricing on request.