Comprehensive support for payment and e-money institution licensing in the Netherlands.
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Why choose the Netherlands?
The Netherlands is an established European fintech hub with a developed payments market and strong professional services ecosystem.
Pragmatic regulator for distributed teams
A practical regulatory approach for fintechs with international operations and distributed teams.
Low local staffing requirements
Key management functions must be local, but certain operational functions can be outsourced.
Developed financial and banking ecosystem
Access to experienced banks, payment providers, fintech partners and professional advisers.
Key requirements for Dutch Payment Institution and E-Money Institution applications
Dutch PI and EMI applicants must demonstrate sufficient local substance, sound governance, financial resilience and robust safeguarding, compliance, risk and technology frameworks to meet DNB requirements.
01
Dutch legal entity and operational presence
The applicant must establish an appropriate legal and operational structure in the Netherlands, which Advapay can help with.
The company must demonstrate that its management, governance and key business functions are genuinely organised in the Netherlands rather than existing only as a formal registered address. DNB recognises that some operational activities may be performed within a broader group structure, provided the Dutch institution maintains adequate local substance, governance, oversight and accountability.
The operational setup must be proportionate to the scale, complexity and risk profile of the planned business.
02
Two day-to-day policymakers in the Netherlands
The day-to-day management of the company must be carried out by at least two natural persons working from the Netherlands.
DNB expects management structures to promote balanced decision-making, effective challenge and clear accountability across the organisation. Having at least two policymakers helps ensure that important decisions are subject to discussion and challenge rather than relying on a single viewpoint.
The policymakers must have sufficient knowledge, experience, availability and authority to manage the regulated business effectively.
03
Governance and organisational structure
The company must establish a clear, balanced and appropriate organisational structure.
Responsibilities between directors, compliance, risk management, internal control, information security and operational functions must be clearly defined.
The applicant must explain how decisions will be made, how risks will be monitored, how conflicts of interest will be managed and how the management body will maintain effective oversight of the business.
The governance structure must also reflect any outsourcing arrangements, group relationships and international operations.
04
Fit and proper assessment
De Nederlandsche Bank assesses the suitability and integrity of controllers, policymakers and co-policymakers involved in the business.
The assessment may consider professional experience, knowledge of financial services, regulatory competence, reputation, financial soundness, previous management responsibilities and potential conflicts of interest.
The company must provide complete and transparent information about the relevant individuals and their proposed responsibilities.
05
Transparent ownership and control structure
The applicant must have a transparent legal and ownership structure.
The application must include information about shareholders, group companies, qualifying holdings and persons who directly or indirectly control the business.
Companies or individuals wishing to acquire or increase a qualifying holding may need to obtain prior approval from De Nederlandsche Bank.
06
Safeguarding customer funds
Protecting customer funds is one of the most important requirements for Payment Institutions and E-Money Institutions.
Applicants must demonstrate how customer funds will be identified, segregated and protected from the institution’s own assets. DNB will assess the proposed safeguarding arrangements, account structure, operational processes and governance framework as part of the licence application.
Most institutions rely on dedicated safeguarding account structures with banking partners, supported by documented safeguarding procedures and ongoing reconciliation controls.
07
Minimum own funds and solvency
Initial capital
The initial capital requirement is EUR 125,000 for a Payment Institution and EUR 350,000 for an E-Money Institution. Applicants must also demonstrate that they have sufficient financial resources to support the proposed business and meet ongoing own funds requirements.
Ongoing own funds
The institution must maintain sufficient own funds on an ongoing basis. The required amount depends on the payment services provided and the applicable regulatory capital calculation method.
08
Professional indemnity insurance
This requirement applies only to institutions providing Payment Initiation Services (PIS), Account Information Services (AIS), or both.
Where the company also holds, or applies for, another licence, the professional indemnity insurance requirement applies in addition to the minimum own funds requirements.
The required level of insurance depends on the services provided.
09
Risk management and internal controls
The applicant must identify the operational, financial, regulatory, security and integrity risks connected with its business model.
The application must explain how these risks will be assessed, monitored, controlled and reported.
The company must establish internal control procedures, risk ownership, escalation processes and management reporting appropriate to the size and complexity of the business.
10
Compliance and integrity framework
The company must establish policies and procedures designed to support ethical and compliant business operations.
This includes customer due diligence, sanctions compliance, transaction monitoring, reporting of unusual transactions, prevention of conflicts of interest and controls for employees working in integrity-sensitive positions.
The application must also include a General Risk Assessment (GRA) and a Systematic Integrity Risk Analysis (SIRA), which identify the institution’s risks and drive the measures to mitigate them.
11
Information technology and security
The applicant must provide detailed information about its information systems, technical infrastructure, security arrangements and operational resilience framework.
This includes authentication and access controls, cybersecurity measures, incident management, outsourcing arrangements, business continuity planning, disaster recovery capabilities and the protection of sensitive customer information.
The application should demonstrate how ICT risks are identified, monitored and managed, how critical service providers are overseen, and how the institution can continue operating during technology disruptions or cyber incidents.
The technology and security framework should be proportionate to the company’s business model, transaction volumes, outsourcing arrangements and risk profile.
12
Business continuity and recovery planning
The company must explain how it will continue providing critical services during operational disruption, cyber incidents, supplier failures or other unexpected events.
The application should include business continuity arrangements, incident response procedures, recovery measures and an exit or wind-down plan.
These documents should demonstrate that the institution can protect customers and manage an orderly interruption or closure of regulated services.
13
Outsourcing governance
Many Payment Institutions and E-Money Institutions rely on third-party providers for technology, operations, compliance support and other key business functions.
While outsourcing can improve efficiency and scalability, responsibility for regulated activities remains with the licensed institution.
Applicants should demonstrate how outsourced service providers will be selected, monitored and governed, particularly where they support critical or important functions.
We assist in the full licensing process of obtaining an E-money or Payment Institution licence in the Netherlands
If you are looking to obtain an Authorised Payment Institution or Electronic Money (E-Money) Institution licence in the Netherlands, Advapay can offer you its legal, technical and business expertise and consulting support.
01
Application preparation, communication with the regulator, business services
Filling out an application form
Communication with regulatory authority during the application phase
Assistance in the development of a business plan
Assistance in the opening of safeguarding accounts
Company formation, staffing services
02
Preparation of legal, financial and IT documents
Legal documents – AML, KYC, IT/Security policies, etc.
Financial documentation – 3-years financial forecast, P&L statement, the flow of funds
Company operational documentation – internal policies, risk operation policies, internal audit, etc.
IT documentation
Regulator
The regulator of financial market in the Netherlands is De Nederlandsche Bank (DNB). DNB is committed to a stable financial system: stable prices, solid financial institutions, and properly functioning payment transfers. In order to provide electronic money or payment services, you must submit an application to DNB and obtain authorisation to offer such services.
Overview of the fintech market
InnovationHub
If you are an innovative financial services or products provider, you can visit the InnovationHub, a joint initiative of supervisors DNB and the Authority for the Financial Markets (AFM).
The InnovationHub offers innovative entrepreneurs and incumbent market participants the opportunity to discuss regulatory issues directly with the relevant supervisory authority, irrespective of whether they are subject to supervision.
The Netherlands is becoming a prominent financial hub in Europe
Amsterdam, the capital of the Netherlands is ranked the 3rd best European city for startups and 5th for scale-ups. The Netherlands rank 2nd as biggest fintech nation and the 3rd in VC funding in Europe.
The Netherlands is a home for different start-ups, including fintech. The country has a high adoption rate for tech innovation, making it an ideal location for innovation labs to test new concepts and solutions.
Application and authorisation process
STEP 1: Preparations – the applicant prepares its application for authorisation (with the help of expert)
STEP 2: Application for authorisation – the applicant submits its application that consists from an application form and annexes
STEP 3: Verification for application file – DNB verifies whether the application is complete and includes sufficient information for starting the assessment
STEP 4: Start of assessment – when the application file is complete, DNB starts their assessment of whether all requirements have been met
STEP 5: Screening of policymakers and co-policymakers – the assessment includes screening of policymakers and co-policymakers on suitability and integrity
STEP 6: On-site visit or interview at DNB’s offices (optional)
STEP 7: Request for information from the regulator – issues that need further explanation or supplementation
STEP 8: Intention to reject (optional) – if the regulator intends to reject the application, DNB will give the applicant the opportunity to explain its view
STEP 9: Result – the regulator sends its official decision in a letter
STEP 10: Objection and appeal – the applicant can object and appeal against DNB’s decision
Terms
The statutory consideration period for an application to be authorised as an electronic money institution is three months. The consideration period will start when the regulator receives all information that is required to take a decision.
Payment and E-Money Institution (Netherlands) licence fees
A fee for considering applications for authorisation
DNB charges a fee for considering applications for authorisation. The fee applies regardless of whether DNB grants or reject the application or the applicant withdraws the application, or DNB ceases consideration during the procedure.
The fee for consideration of an application for authorisation as an electronic money institution is EUR 6,800.
Fee for regular supervision
DNB also charges electronic money and payment institutions an annual fee to cover the costs of their regular supervision on these institutions.
Read more about the features of obtaining a Payment or E-Money licence in the Netherlands in our previous article:
Documents
Business case
1) Programme of operations and business plan
2) Marketing plan
3) Funds flow chart
4) Recovery and exit plan
Operational management set-up for sound business operations
The company must be structured in such a way as to ensure sound and ethical business operations. This means that the applicant must analyse the operational risks to which the company is exposed and take measures to mitigate these risks. The applicant must submit information to cover the following areas:
5) Risk analysis for the purpose of managing operational processes and operational risks.
6) Risk management framework
7) A clear, balanced and adequate organisational structure
8) Compliance function
9) Internal control function
10) Procedures manual
11) External audit
12) International services
13) Information systems, infrastructure and security
14) Authentication
15) Secure communication
16) Data collection
17) Outsourcing
18) Incident management
19) Business continuity management
20) Sound remuneration policy
21) Oath or affirmation
22) Training
Ethical business operations
The company must ensure ethical business operations as is one of the pillars of trust and as such it is a precondition for the company`s proper functioning. The company must submit documentation to cover the following areas:
23) Systematic integrity risk analysis (SIRA)
24) Preventing conflicts of interest
25) Propriety of staff working in integrity-sensitive positions
26) Customer due diligence
27) Policy and procedures on sanctions legislation
28) Transaction monitoring and reporting of unusual transactions
Fit and proper assessment of policymakers and co-policymakers
29) Fitness of policymakers
30) Integrity of policymakers and co-policymakers
Two day-to-day policymakers working from the Netherlands
31) The day-to-day management of your company must be in the hands of at least two natural persons. These two individuals must work from the Netherlands, in order to ensure compliance with the four-eyes principle, or the principle of dual day-to-day management
Transparent control structure
32) The applicant’s company must have a transparent control structure. The applicant must provide a diagram of the legal structure of which the company is a part.
Qualifying holdings
33) Companies wanting to acquire or enlarge a qualifying shareholding or a controlling interest in the applicant’s company must obtain DNB’s prior permission.
Securing the funds of payment service users
Method 1: Customer accounts foundation
The funds are paid into a separate account that cannot be touched by your company’s other creditors. In practice, this means that a separate, independent custodian must be appointed to manage the funds entrusted by payment service users – known as a customer accounts foundation.
Method 2: Insurance policy or comparable guarantee
If you opt for method 2, you need to submit a statement that the funds entrusted are covered by an insurance policy, or a comparable guarantee from an insurance company or a bank that is not part of the same group as the applicant’s company.
Minimum own funds and solvency
Minimum own funds
Your company’s initial capital amounts to €125,000 for the provision of payment services and €350,000 for the issuance of electronic money.
Required actual own funds as part of solvency
As part of solvency requirements, your company must hold a sufficient amount of actual own funds for the purposes of the solvency test. The method for calculating the minimum size of the regulatory capital is determined on the basis of the payment services provided by your company.
Liability insurance
This section only applies to you if you only provide payment initiation services and account information service or both.
If your company also holds or is applying for a licence for other services, the indemnity insurance requirement applies cumulatively to the minimum own funds and actual own funds requirements.
The liability to be insured and level of coverage depends on the type of service provision.
Jurisdictions
we cover
We have a strong focus on fintech businesses like digital banks, e-wallets, fiat-crypto wallets, e-commerce banking and remittance.
