DNB will assess every Dutch payment institution and e-money institution against PSD3 within 27 months of entry into force. Dutch advisers expect existing institutions to submit the information PSD3 lists rather than a full new application, but DNB's assessment will cover the whole of Title II. This checklist turns DNB's 2026 publications into controls a compliance team can test now. The EU-wide process is in our PSD3 re-authorisation guide.
The Dutch market
The EBA Central Register listed 65 authorised payment institutions and 28 EMIs with a Dutch home licence at 30 October 2026, together with 36 exempt payment institutions and 25 EMIs under a waiver. 71 Dutch firms passport into other member states. Acquirers and payment service providers for online merchants are a large part of the authorised group.
| Milestone | When |
|---|---|
| Council first reading position adopted | 29 October 2026 |
| European Parliament plenary approval | Expected around the end of 2026 |
| Entry into force | 20 days after publication in the Official Journal |
| National PSD3 rules and the PSR apply | 21 months after entry into force |
| Existing institutions must have shown compliance | 27 months after entry into force (plus up to 3 months in exceptional cases) |
The Netherlands will transpose PSD3 through amendments to the Financial Supervision Act (Wft) and related regulations.
Checklist 1: the exit plan, tested against DNB's review
In March 2026 DNB reported five weaknesses in the exit plans it reviewed. Use them as the test.
| DNB finding | Control | Evidence |
|---|---|---|
| Plans out of date | Plan reviewed at least annually and on major change, uploaded to MijnDNB | Version history, board approval, upload confirmation |
| Repayment timelines too optimistic | Repayment modelled for blocked, dormant and unreachable customers | Repayment test, assumptions log |
| Dependencies missing | Group and third-party dependencies mapped and agreed in writing | Dependency register, support letters |
| Scenarios too narrow | Includes sudden parent collapse and partial sale | Scenario analysis with liquidity needs |
| Costs underestimated | Full cost to completion, minimum capital held until surrender | Costed plan, capital projection |
DNB also stressed that a licence can only be surrendered once all client balances have been paid out. The PSD3 winding-up plan must provide for returning safeguarded funds in a disorderly wind-down, so the repayment model is the centre of the plan. Our winding-up plan guide covers the rest.
Checklist 2: safeguarding structure
DNB's revised application notes describe three methods: a client funds foundation, a separate asset account, and an insurance policy or guarantee.
- Confirm which structure the institution uses and that its documents match DNB's notes: foundation statutes and board, account in the foundation's or separate asset account's name, bank confirmation.
- Move e-money safeguarding to the end of the business day after receipt.
- Where funds sit with one bank, add a second account and set allocation limits.
- Check the foundation can pay customers directly in a wind-down, with signing authorities that do not depend on the institution's management.
- Prepare user information on the method and applicable insolvency law.
- Keep 12 months of daily reconciliations with breaks explained.
Our PSD3 safeguarding checklist has the full control set, and our safeguarding team reviews Dutch structures.
Checklist 3: acquiring and merchant flows
- Map settlement flows for each acquiring model, including international card scheme flows addressed in the PSD3 recitals.
- Identify where funds are held at the end of the business day after receipt and safeguard them.
- Review each marketplace or platform client against the tighter commercial agent exclusion, and decide whether the client needs its own licence or comes under the institution's.
- Reflect reserves, rolling holds and chargebacks in safeguarding and the winding-up plan.
Checklist 4: exempt firms and waived EMIs
- Measure current and projected transaction values against the PSD3 exemption conditions.
- Note that waived EMIs have a longer transition period than authorised institutions, and confirm the timetable with DNB.
- Decide whether full authorisation is the better route for growth, passporting or bank relationships.
Checklist 5: capital, services and passports
- Map every activity to the PSD3 service list; former EMIs authorised only for issuance need related payment services listed expressly.
- Recalculate initial capital by service, added together, and ongoing own funds; see our own funds calculation guide.
- Project capital three years ahead, approved by the board.
- Align passports with the PSD3 service list.
Checklist 6: governance, AML and DORA
- Map the governance and internal control framework to PSD3 requirements.
- Confirm head office and part of the payment business are in the Netherlands.
- Refresh the AML risk assessment and align with the EU AML Regulation from 10 July 2027.
- Keep the DORA register of information current and test incident reporting.
Running the repayment test
The repayment model is where DNB found plans most optimistic, so test it rather than estimate it. Take a recent date and produce, from live systems, a full list of customers with balances, contact details and last activity date. Split the list into groups: active and contactable, active with payment blocks or open investigations, dormant, and unreachable. For each group, estimate how long repayment would take, what checks are needed before paying out, and what it would cost. Include merchants with reserves or rolling holds, whose balances may not be payable until chargeback periods expire. Record the time it took to produce the list. If it took more than a day or two, that is a finding in itself. The test result, with assumptions, is strong evidence for both DNB's exit plan expectations and the PSD3 winding-up plan.
Evidence index for a Dutch file
| File section | Core documents |
|---|---|
| Programme of operations | PSD3 service list, merchant segments, passports |
| Business plan and capital | Three-year projection, own funds calculation, board approval |
| Safeguarding | Foundation or separate asset account documents, bank confirmations, reconciliations |
| Governance and AML | Organisation chart, policies, risk assessment, monitoring |
| ICT and continuity | DORA register, incident procedure, tests |
| Exit and winding-up plan | Current MijnDNB version, repayment test, dependency register, costs |
Questions for the board
A Dutch board should be able to show: a current exit plan in MijnDNB addressing each finding from DNB's 2026 review; a safeguarding structure that meets next business day timing without relying on one bank; a reviewed position on each platform or marketplace client under the commercial agent exclusion; a decision for any exempt or waived entity in the group; a three-year capital projection under PSD3; and a named owner and timetable for the file. Each item should be minuted when it is approved.
Building a complete file
DNB's application process now separates a completeness check from the substantive assessment, and DNB generally asks only once for missing documents. Apply the same discipline to the PSD3 file: an index of every required item, cross-referenced to evidence, reviewed by someone outside the team that wrote it. Our compliance support team prepares PSD3 files for Dutch institutions. See also our Netherlands EMI licence guide.