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Licence guide

Netherlands electronic money institution licence.

E-money issuers choose the Netherlands for a regulator that publishes its forms, notes and success factors, and for the customer accounts foundation, a safeguarding structure Dutch banks know well.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
DNBRegulator
€350,000Initial capital
€10,400Application fee
6 to 8 monthsOur realistic timeline
EU and EEAPassporting

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 8 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for two directors based in the Netherlands, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. The permissions, the own funds under Methods D and B and the safeguarding route are confirmed in a written proposal the same day, with an introductory meeting with DNB’s Expert Centre on Market Access arranged before filing.
  2. Application pack. The application form and annexes, three-year projections, the systematic integrity risk analysis, the policymaker files and a declaration of no objection request for each 10% holder, submitted through MyDNB as one complete file.
  3. Banking. The customer accounts foundation and its account, or a segregated account, are opened and blocked before the licence is granted, or a bank commitment letter is supplied; the firm arranges these and the operating accounts through its relationships.
  4. Regulator engagement. DNB requests missing documents once, so each response is complete and on time, with the policymakers recruited before filing and the declarations of no objection running in parallel within 62 business days, until the licence decision.

Key people, banking and technology

You will need at least two directors who run the business day to day from the Netherlands, plus any supervisory board members.

Key peopleThe firm introduces candidates for two directors based in the Netherlands from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • A Dutch EMI issues e-money and provides payment services across the EU and EEA on one authorisation, under DNB’s prudential supervision and the AFM’s conduct supervision.
  • Initial capital is €350,000; own funds are at least 2% of average outstanding e-money plus Method B capital for other payment services.
  • The application fee is €10,400, payable even if the application is refused.
  • Three months from a complete application by statute; DNB states the total is usually longer.
  • At least two natural persons must run the business from the Netherlands; every 10% shareholder needs a declaration of no objection.
  • Safeguarding is most often through a customer accounts foundation, a Dutch structure that ring-fences customer funds.

Who needs the licence

A business issuing stored value to customers in the Netherlands or, through passporting, across the EU and EEA needs a DNB authorisation. The Netherlands is a well-regarded EU base with a regulator that publishes its application forms, explanatory notes and success factors, and a safeguarding structure, the customer accounts foundation, that banks understand. An EMI may provide every payment service under the same licence.

What DNB requires

  • Legal form and location. A company with its registered office in the Netherlands; day-to-day management by at least two natural persons working substantially from the Netherlands, with a substantial presence of the management board.
  • Governance. Two policymakers under the four-eyes principle, each assessed for suitability and propriety; an independent supervisory board where one exists; a systematic integrity risk analysis as a separate document; a declaration of no objection for every holder of 10% or more, decided within 62 business days.
  • Safeguarding. A customer accounts foundation (stichting derdengelden), a segregated account with an authorised institution, or an insurance policy or guarantee from outside the group; the account must be opened and blocked, or a bank commitment letter supplied, before the licence is granted.
  • Application pack. The application form and annexes submitted through MyDNB after contact with the Expert Centre on Market Access: business plan, three-year projections, programme of operations, governance, outsourcing, IT, security, the integrity risk analysis and the policymaker files.
  • Conduct supervision. The Netherlands Authority for the Financial Markets supervises conduct; DNB supervises prudential matters and licensing.
  • Capital. Initial capital of €350,000 and own funds thereafter under Method D (2% of average outstanding e-money) plus Method A, B or C for unrelated payment services, generally Method B.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own funds (Method D)2% of average outstanding e-money
Unrelated payment servicesMethod B generally; all three calculations submitted
ExemptionOutstanding e-money not above €5 million and €150 per account

DNB applies the deductions in the capital requirements regulation to the own funds calculation.

Timing

FigureValueSource
Statutory decision period3 months from a complete application, suspended during information requestsFinancial Supervision Act (Wft)
Regulator’s published figureDNB states the total period tends to be longer than three monthsDNB application process timeline
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Application fee€10,400Payable on application; non-refundable
Annual supervisory feeSet annuallyDNB’s regular supervision costs are charged to licensed institutions
Initial capital€350,000Held before authorisation
Professional feesFixed, in writingQuoted after scoping

Exemption from authorisation

A firm whose outstanding e-money stays below €5 million, with no more than €150 held on any e-money account, no agents and clean antecedents, may register under the exemption. It is registered but not supervised by DNB and must say so to customers; it may not passport; expansion outside the Netherlands must be reported.

Passporting and scope

A Dutch EMI passports throughout the EU and EEA on notification to DNB after authorisation, by branch, agent or distributor, or cross-border services.

Why applications are delayed

DNB publishes its success factors for market access.

  1. Incomplete or inaccurate applications: DNB requests missing documents once and may then dismiss the application.
  2. Insufficient substance in the Netherlands: the management and the decisions must be here.
  3. Late recruitment of policymakers, integrity issues, and late applications for declarations of no objection by shareholders.

Banking

An EMI needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Netherlands and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

How long does a DNB EMI licence take?

Three months from a complete application by statute, suspended for each information request. DNB states the total tends to be longer; the firm plans for six to eight months after submission.

What is a stichting derdengelden?

A customer accounts foundation: a separate legal entity that holds customer funds on the EMI’s behalf so that they are ring-fenced from the EMI’s creditors. It is the most common Dutch safeguarding method.

How many people must be in the Netherlands?

At least two natural persons in day-to-day management, working substantially from the Netherlands, each assessed by DNB for suitability and propriety.

Is the application fee refundable?

No. The €10,400 fee is payable even if the application is withdrawn or refused.

Can a Dutch EMI serve the UK?

Not under the Dutch licence. Groups serving both markets hold an FCA authorisation and a Dutch authorisation.

References

  1. DNB: licensing requirement for payment service providers
  2. DNB: success factors for market access
  3. Regulation on the funding of financial supervision (one-off acts)
  4. DNB: EMI authorisation overview
  5. DNB: explanatory notes to the EMI application form
  6. DNB: exemption from the authorisation requirement (EMI)

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.