Netherlands EMI Licence: DNB Requirements, Capital, Fees and Timeline

Who a Dutch EMI licence suits

The licence suits firms that want a large home market, a regulator with a strong reputation, and a base for EEA expansion. DNB notes that many new payment institutions have entered the Dutch market in recent years and that the number of institutions has grown significantly since 2016.

For UK firms it replaces the passport lost on 31 December 2020. The Dutch entity must be run from the Netherlands, with at least two policymakers based there, so it is a real operating company rather than a booking entity.

It is a demanding route. DNB's fees are higher than in Lithuania, its integrity supervision is intensive, and Dutch law adds its own rules, such as the bonus cap on remuneration and the financial sector oath.

Licence or exemption

Small issuers can ask DNB to register them as an exempt EMI instead of applying for a licence. DNB enters them in its public register once they show they meet the conditions of the Exemption Regulation. Exempt EMIs are not under DNB's ongoing supervision, but they remain subject to AFM conduct rules and to the Wwft, so they must carry out customer due diligence and report unusual transactions to FIU-Netherlands.

If an exempt EMI expects to pass the EUR 5 million limit or to serve customers outside the Netherlands, it must tell DNB and apply for a licence in good time. It cannot keep relying on the exemption once the conditions are no longer met.

Capital, own funds and solvency

The minimum own funds for an EMI are EUR 350,000, and DNB requires proof of deposit at submission. For solvency, the EMI must hold at least 2 per cent of average outstanding e-money (Method D) for its e-money activity.

For payment services not related to e-money, DNB says the minimum is generally calculated under Method B, which scales with payment volume, but it asks applicants to submit calculations under all three methods. The total requirement is the sum of the e-money and payment services parts.

DNB reminds applicants to deduct items such as intangible assets, current-year earnings not yet confirmed by the auditor and deferred taxes, as defined in the Capital Requirements Regulation. Applicants fill in DNB's prudential reporting templates for the next three years in line with their forecasts.

Safeguarding customer funds: the three Dutch methods

Method 1 is a customer accounts foundation (stichting derdengelden): a separate legal entity whose only purpose is to receive, manage and pay out customer funds. Its board members are assessed for integrity, and it may not trade, lend or take on other commitments.

Method 2 is a segregated assets account held by an entity legally authorised to manage such accounts, used only for third-party funds and protected from the EMI's creditors.

Method 3 is an insurance policy or guarantee from an insurer or bank outside the EMI's group, backed by a reconciliation process showing that cover is sufficient at all times.

For methods 1 and 2, DNB requires proof of an opened account or a bank-signed commitment letter confirming that customer acceptance is complete and the account is open and blocked until the licence is granted. DNB updated its notes on 19 March 2026 because this evidence was frequently missing.

Substance and governance in the Netherlands

• - At least two day-to-day policymakers working from the Netherlands, to secure dual management
• - A transparent control structure: the formal structure must match the actual one and must not obstruct supervision, for example by making people at the company subject to the laws of non-EU states
• - A governance structure that ensures sound and independent operations, for example through a supervisory board, with independence clearly defined in a group
• - Suitability and integrity assessments of policymakers, and a declaration of no objection for shareholders with 10 per cent or more
• - Separate compliance, risk management and internal audit functions, with the compliance officer's job profile and an annual compliance plan
• - A remuneration policy within the Dutch bonus cap
• - The financial sector oath or affirmation for people working in the Netherlands whose work can materially affect the risk profile or who are directly involved in financial services

How DNB processes an application

Applications are submitted through DNB's Digital Supervision Portal, which requires eHerkenning, a Dutch business login. DNB publishes detailed explanatory notes in English and recommends using them as a checklist.

Phase 1 checks completeness. If documents are missing, DNB generally asks once. If the file is still incomplete, phase 2 does not start and the application may be dismissed, with the fee still due. Phase 2 is the substantive assessment of organisation, sound business operations, governance and safeguarding. DNB may schedule meetings, which suspends the clock, and assesses the decision makers.

DNB observes that applications are more often complete and of higher quality when the applicant has sought advice from a legal adviser or accountant who knows the Wft.

DNB's supervisory stance, 2024 to 2026

DNB is direct about the sector. In Integrity Supervision in Focus 2026, published on 25 June 2026, it says it has found shortcomings at a significant number of payment institutions and EMIs, especially in transaction monitoring and the underlying SIRA and customer due diligence, and that a large share of the sector is running excessive risk. It is also scrutinising virtual IBANs and white labelling, where a licensed institution lets other firms onboard customers on its platform.

On 13 July 2026 DNB published an administrative fine of EUR 2.65 million on payment institution CCV Netherlands B.V. for failing to monitor transactions continuously. Its monitoring system was not fed fully and on time with all merchant transactions for over two years, and alerts were closed without adequate reasons, with transactions closed in bulk. DNB raised the EUR 2.5 million base fine because of an earlier fine, then reduced it for CCV's recovery plan.

Other 2026 actions point the same way. On 13 March DNB published the results of a review of exit plans, noting that a licence can only be handed in once all customer funds have been paid out. On 3 June it published findings from an examination of payment fraud controls at seven banks, payment institutions and EMIs.

Passporting from the Netherlands

A DNB licence allows the EMI to operate in any EEA state without a second licence. The EMI notifies DNB, which notifies the host regulator. Under PSD2 the home regulator passes the information on within 1 month of receiving it in full, the host has 1 month to respond, and the home regulator decides within 3 months.

Exempt EMIs cannot passport and may not expand their activities outside the Netherlands.

Ongoing obligations after authorisation

• - Prudential reporting to DNB on own funds and solvency using DNB's reporting templates
• - An up-to-date exit plan, uploaded in MyDNB, covering bankruptcy of the parent, dependence on group and outsourcing partners and the time needed to return all customer funds
• - Wwft customer due diligence, transaction monitoring and reporting of unusual transactions to FIU-Netherlands, with an annual integrity risk survey (IRAP) to DNB
• - DORA rules on ICT risk, incident reporting and the register of information on ICT providers, which apply from 17 January 2025
• - Fit and proper assessments before new policymakers take office
• - Annual DNB and AFM levies, and AFM conduct supervision of customer treatment
• - Notification to DNB before material changes to safeguarding, outsourcing or the control structure
• - From 9 April 2027, the ability to send and receive instant euro payments

PSD3 and e-money tokens

Parliament and Council negotiators agreed PSD3 and the Payment Services Regulation on 27 November 2025, and the final compromise text went to EU ambassadors on 17 April 2026. Under that text, e-money issuance becomes a payment service, initial capital for it falls to EUR 250,000, and existing EMIs have up to 27 months after entry into force to show DNB they comply.

Under MiCA, only a credit institution or an EMI can offer an e-money token to the public. A Dutch EMI must notify DNB at least 40 working days before an offer, and DNB charges EUR 4,800 for handling that notification.

Pre-application checklist

• - Perimeter analysis confirming e-money issuance and testing the exemption
• - Clear description of each service with a flow-of-funds chart
• - Two day-to-day policymakers working from the Netherlands, recruited and pre-checked
• - Key function holders for compliance, risk and internal audit identified
• - DNO applications started for every shareholder with 10 per cent or more
• - EUR 350,000 deposited, with proof ready to file
• - Safeguarding method chosen and a bank commitment letter or account evidence obtained
• - Three-year forecasts and DNB prudential templates, with CRR deductions applied
• - SIRA and Wwft and sanctions procedures matched to the product
• - Governance documents, including supervisory board arrangements where used
• - Remuneration policy within the bonus cap and an oath procedure
• - ICT, outsourcing and incident processes meeting DORA
• - Recovery and exit plan with realistic timelines for returning customer funds
• - eHerkenning access to DNB's Digital Supervision Portal