An electronic money institution is a company, other than a bank, licensed to issue electronic money: a stored monetary value that a customer pays for in advance, holds on an account, card or wallet, and spends with third parties. Any party issuing e-money in the Netherlands needs a DNB licence, or must be exempt or excepted, and may start only after DNB has granted the licence or registered the exemption.
The licence requirement is in Article 2:10a of the Financial Supervision Act (Wet op het financieel toezicht, Wft), which implements the EU E-Money Directive (Directive 2009/110/EC). The payment services an EMI may also offer come from the second Payment Services Directive (PSD2), implemented in the Wft. Anti-money laundering obligations are set by the Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft).
DNB grants the licence and carries out prudential and integrity supervision, which covers own funds, safeguarding, governance and financial crime controls. The AFM supervises market conduct: how the EMI informs, treats and handles complaints from its customers.
An EMI cannot take deposits or pay interest on e-money balances. If customers will not hold stored balances and funds only pass through, a payment institution licence is usually the better fit; the firm's Netherlands payment institution licence service covers that route.
DNB offers a registration-based exemption for small issuers. It suits closed or low-value products, not a business that intends to scale or serve other EU countries.
| Point | Licensed EMI | Exempt EMI |
|---|---|---|
| Outstanding e-money | No limit | At most EUR 5 million |
| Maximum per instrument or account | No limit | EUR 150 at any one time |
| Minimum own funds | EUR 350,000 | None |
| Safeguarding | Required | Required: customer accounts foundation, insurance or guarantee |
| DNB supervision | Full prudential and integrity supervision | Not under DNB's regular supervision |
| EEA passporting | Available after notification | Not available |
| Issuing through agents | Payment services only | Not permitted |
An exempt EMI must tell DNB before it expects to exceed EUR 5 million and must stop issuing e-money if it no longer meets the conditions, so DNB advises preparing a licence application early. The Wwft and AFM conduct supervision apply in both cases.
The E-Money Directive sets minimum initial capital of EUR 350,000. DNB requires proof, with the application, that the statutory minimum has been deposited, for example a bank statement or a bank's letter confirming that the account is open and blocked until licensing.
| Requirement | Amount | Source |
|---|---|---|
| Minimum initial capital | EUR 350,000 | Directive 2009/110/EC, Article 4 |
| Own funds for e-money | At least 2% of average outstanding e-money | Directive 2009/110/EC, Article 5 |
| Own funds for unrelated payment services | Calculated under the PSD2 methods | Directive (EU) 2015/2366, Article 9 |
DNB also asks for financial projections for the current year and the next three years, including stress scenarios, and a budget for the first three financial years. The plan should show the EMI meeting its own funds requirement and covering its costs if volumes arrive later than forecast.
DNB's application notes require two day-to-day policymakers working from the Netherlands, so that every key decision is taken by at least two people. In everyday terms, these are the executive directors who run the business, typically the chief executive and the finance or operations director. Their duties cannot be outsourced.
Policymakers, meaning management board and supervisory board members, are tested for both suitability (knowledge, skills and experience) and propriety (integrity). Co-policymakers, people who can significantly influence day-to-day management without sitting on the board, are tested for propriety. DNB advises recruiting early and checking in advance for anything that could delay the assessment.
The management board must perform its work substantially from the Netherlands, and the EMI must show a real presence: an office, staff and control functions able to run the activities. A supervisory board is the usual way to show sound, independent governance, particularly within a group.
Anyone acquiring a qualifying holding needs a declaration of no-objection from DNB under Article 3:95 of the Wft. DNB recommends starting this process early, because it requires substantial documentation and must be in place when the licence is granted.
A Dutch EMI must protect the funds it receives for e-money so that customers are repaid if the EMI becomes insolvent. The application states the chosen method and includes all supporting documents. The methods are:
Under the E-Money Directive the funds must be safeguarded no later than five business days after the e-money is issued. DNB expects proof that the safeguarding account has been opened, or a bank's signed commitment, when the application is filed. The firm's safeguarding and client assets service sets up these structures and the reconciliation behind them.
DNB requires a systematic integrity risk analysis (SIRA): a separate, verifiable document that scores each integrity risk before and after controls, for likelihood and impact. It must cover conflicts of interest, money laundering, terrorist financing, sanctions breaches, and internet fraud and scams, in different scenarios. A governance document sets out who runs the SIRA, how business functions take part and how it is reviewed at least once a year. The management board is responsible for it.
Since 17 January 2025 the ICT requirements in DNB's application notes are to be read as the requirements of the Digital Operational Resilience Act (Regulation (EU) 2022/2554): ICT risk management, incident reporting, business continuity and ICT third-party arrangements. DNB also asks for an IT strategy, an IT and security policy, a risk management model and penetration testing at least once a year.
Outsourcing is permitted unless it hampers compliance or continuity. Each material outsourcing needs a written agreement and its own risk analysis, and the agreement must give DNB information and on-site inspection rights, allow changes to how the work is done and set out termination arrangements. A copy of the outsourcing policy is submitted with the application.
The application form follows the structure below. Each section must show, with documents, how the EMI meets the requirement; DNB notes that policies written for the specific business, rather than generic templates, make the difference.
| Form section | What it covers |
|---|---|
| 1. General information | The applicant, group and services |
| 2. Business case | Business plan, three-year budget, projections with stress scenarios, recovery and exit plan |
| 3. Sound business operations | Governance, risk management, outsourcing, IT and security, continuity |
| 4. Ethical business operations | SIRA, customer due diligence, sanctions and integrity policies |
| 5. Fit and proper assessment | Policymakers and co-policymakers |
| 6. Two day-to-day policymakers | Working from the Netherlands |
| 7. Transparent control structure | Ownership and control chart |
| 8. Qualifying holdings | Shareholders and declarations of no-objection |
| 9. Securing funds of e-money users | Safeguarding method and documents |
| 10. Minimum own funds and solvency | Capital deposit and own funds calculation |
| 11. Liability insurance | Cover for payment initiation and account information, where offered |
Existing companies also submit audited financial statements for the past three years, or a signed opening balance sheet if none exist. The recovery and exit plan must explain how customer funds would be returned and must be reviewed at least once a year.
The statutory decision period for an EMI licence is three months. It starts only when DNB has all the information it needs, and it is suspended while DNB waits for missing information or holds a meeting. DNB notes that total processing time often exceeds three months for that reason.
| Item | Figure | Source |
|---|---|---|
| Statutory decision period | 3 months from a complete file | DNB |
| Submission to licence | 6 to 8 months | Firm's planning figure |
| Licence application fee | EUR 10,400 | Fee regulation, Article 5, row Wft.D1.05, in force since 22 September 2026 |
| Annual supervision fee | Set each year by DNB | DNB |
The application fee is charged once for processing the application, whatever the outcome. The larger costs are the capital, the Dutch management team, systems and the safeguarding arrangement.
A licensed Dutch EMI can issue e-money and provide its payment services in every other European Economic Area state on the basis of its DNB licence, after notifying DNB, which informs the host state's authority. It can do so cross-border or through a branch, and it can distribute e-money through distributors. The host state's consumer, anti-money laundering and marketing rules still apply.
UK firms lost their EU passporting rights on 31 December 2020, so a UK EMI that wants to serve Dutch or other EU customers needs an EU-licensed entity. Firms choosing between the Netherlands and other member states can compare them in the firm's EU jurisdiction comparison.
Under the Markets in Crypto-Assets Regulation (MiCA), an EMI may issue e-money tokens, which are stablecoins referencing a single official currency such as the euro, after notifying a crypto-asset white paper and meeting MiCA's reserve and redemption rules, as set out in the firm's guide to issuing an EMT in Europe.
The proposed PSD3 and Payment Services Regulation would bring EMIs into the payment institution framework. The Council and Parliament reached political agreement in late 2025; at the date of review the texts had not been formally adopted or published in the Official Journal, and existing EMIs are expected to receive a transition period. The firm's PSD3 and PSR briefing explains what to prepare. The firm's Netherlands EMI licence service prepares the full DNB application and manages the review through to licensing.
EUR 350,000, deposited and evidenced before DNB grants the licence. After licensing, own funds must be at least 2% of average outstanding e-money.
EUR 10,400 under the fee regulation in force since 22 September 2026. An annual supervision fee applies once licensed.
The statutory period is three months from the date DNB has all the information it needs. The firm plans 6 to 8 months from submission to licence.
Yes. DNB requires two day-to-day policymakers working from the Netherlands, and the management board must perform its work substantially from there.
A systematic integrity risk analysis: a written assessment of the EMI's money laundering, terrorist financing, sanctions, fraud and conflict of interest risks before and after controls, reviewed at least once a year.
Yes, for issuers with no more than EUR 5 million of outstanding e-money and instruments holding at most EUR 150. Exempt EMIs are not under DNB's regular supervision and cannot passport.
Yes. A licensed Dutch EMI can passport its services to every EEA state after notifying DNB.
DNB grants the licence and supervises prudential and integrity matters. The AFM supervises conduct towards customers.
Buckingham Capital Consulting has obtained e-money authorisations for firms including Dzing Finance, Hryze and Own Solutions since 2013, and prepares Dutch EMI applications to DNB's published requirements. The firm builds the SIRA, safeguarding, governance and DORA frameworks alongside the application, and arranges the safeguarding and operating accounts the EMI needs to launch.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.
This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.