PSD3 in the Netherlands

Key points

  • Dutch payment and e-money institutions must evidence PSD3 compliance to DNB within 27 months of entry into force.
  • DNB's March 2026 exit plan review gives a ready-made test for the PSD3 winding-up plan: currency, realistic timelines, dependencies, severe scenarios and costs.
  • DNB's March 2026 application notes describe three safeguarding structures and the documents behind each, a useful standard for the PSD3 file.
  • Acquirers and payment service providers should test settlement flows against next business day safeguarding and the tighter commercial agent exclusion.
  • 61 Dutch firms operate under a national exemption or waiver and need their own PSD3 decision.
On this page

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.

MilestoneWhen
Council first reading position adopted29 October 2026
European Parliament plenary approvalExpected around the end of 2026
Entry into force20 days after publication in the Official Journal
National PSD3 rules and the PSR apply21 months after entry into force
Existing institutions must have shown compliance27 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 findingControlEvidence
Plans out of datePlan reviewed at least annually and on major change, uploaded to MijnDNBVersion history, board approval, upload confirmation
Repayment timelines too optimisticRepayment modelled for blocked, dormant and unreachable customersRepayment test, assumptions log
Dependencies missingGroup and third-party dependencies mapped and agreed in writingDependency register, support letters
Scenarios too narrowIncludes sudden parent collapse and partial saleScenario analysis with liquidity needs
Costs underestimatedFull cost to completion, minimum capital held until surrenderCosted 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 sectionCore documents
Programme of operationsPSD3 service list, merchant segments, passports
Business plan and capitalThree-year projection, own funds calculation, board approval
SafeguardingFoundation or separate asset account documents, bank confirmations, reconciliations
Governance and AMLOrganisation chart, policies, risk assessment, monitoring
ICT and continuityDORA register, incident procedure, tests
Exit and winding-up planCurrent 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.

References

This article is general information as at 8 November 2026 and is not legal advice.

Frequently asked questions

Do Dutch institutions need a full new DNB application under PSD3?

Advisers expect existing institutions to provide the information PSD3 lists rather than a full application, but DNB will assess compliance with all of Title II.

What did DNB's 2026 exit plan review find?

Plans out of date, optimistic repayment timelines, missing dependencies, narrow scenarios and underestimated costs.

Which safeguarding structures does DNB recognise?

A client funds foundation, a separate asset account, and an insurance policy or guarantee.

What should acquirers check under PSD3?

Where funds sit at the end of the business day after receipt, how card scheme flows are treated, and whether platform clients still fit the commercial agent exclusion.

Do exempt Dutch payment institutions need to act?

Yes. Each should test its volumes against the PSD3 exemption conditions and decide whether to seek full authorisation.

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