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Procedure to Obtain the E-money / EMI Licence in the Netherlands (2026)

Published 28 January 2020 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a Dutch electronic money institution is
  2. Services a Dutch EMI can offer
  3. Licence or exemption
  4. Capital and own funds
  5. People and substance in the Netherlands
  6. Safeguarding customer funds
  7. Integrity, ICT and outsourcing
  8. Documents in the application
  9. The application process
  10. How long it takes and what it costs
  11. Passporting across the EEA
  12. After authorisation, MiCA and PSD3
  13. Frequently asked questions
Key takeaways
  • De Nederlandsche Bank (DNB) licenses electronic money institutions (EMIs) under Article 2:10a of the Financial Supervision Act (Wft); the Dutch Authority for the Financial Markets (AFM) supervises their conduct towards customers.
  • A Dutch EMI needs minimum own funds of EUR 350,000, evidenced by a deposit before the licence is granted, and own funds that keep pace with its outstanding e-money afterwards.
  • DNB's one-off fee for an EMI licence application is EUR 10,400 under the fee regulation in force since 22 September 2026, and an annual supervision fee applies once licensed.
  • The statutory decision period is three months, starting only when DNB has all the information it needs. The firm plans 6 to 8 months from submission to licence.
  • DNB expects two day-to-day policymakers working from the Netherlands, a substantial local presence and a written systematic integrity risk analysis (SIRA).
  • Small issuers with no more than EUR 5 million of outstanding e-money and instruments holding at most EUR 150 can register for an exemption, but are not supervised by DNB and cannot passport.

What a Dutch electronic money institution is

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).

Two supervisors

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.

Services a Dutch EMI can offer

  • Issuing, distributing and redeeming e-money, for example prepaid cards, wallets and e-money accounts with an IBAN.
  • Payment accounts, with cash deposits and withdrawals, card payments, direct debits, standing orders and transfers.
  • Issuing payment instruments and acquiring card payments for merchants.
  • Money remittance, including cross-border transfers.
  • Payment initiation, which moves funds from a customer's bank account to a merchant with the customer's consent.
  • Account information, which gives customers a combined view of their accounts with their consent.

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.

Licence or exemption

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.

PointLicensed EMIExempt EMI
Outstanding e-moneyNo limitAt most EUR 5 million
Maximum per instrument or accountNo limitEUR 150 at any one time
Minimum own fundsEUR 350,000None
SafeguardingRequiredRequired: customer accounts foundation, insurance or guarantee
DNB supervisionFull prudential and integrity supervisionNot under DNB's regular supervision
EEA passportingAvailable after notificationNot available
Issuing through agentsPayment services onlyNot 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.

Capital and own funds

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.

RequirementAmountSource
Minimum initial capitalEUR 350,000Directive 2009/110/EC, Article 4
Own funds for e-moneyAt least 2% of average outstanding e-moneyDirective 2009/110/EC, Article 5
Own funds for unrelated payment servicesCalculated under the PSD2 methodsDirective (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.

People and substance in the Netherlands

Two day-to-day policymakers

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.

Fit and proper assessment

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.

Substance

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.

Shareholders

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.

Safeguarding customer funds

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:

  • A customer accounts foundation (stichting derdengelden), a separate legal entity that holds customer funds in its own bank account.
  • A segregated safeguarding account at a bank, or investment in secure, low-risk assets.
  • An insurance policy or a guarantee from an insurer or bank outside the EMI's group.

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.

Integrity, ICT and outsourcing

Systematic integrity risk analysis

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.

ICT and DORA

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

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.

Documents in 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 sectionWhat it covers
1. General informationThe applicant, group and services
2. Business caseBusiness plan, three-year budget, projections with stress scenarios, recovery and exit plan
3. Sound business operationsGovernance, risk management, outsourcing, IT and security, continuity
4. Ethical business operationsSIRA, customer due diligence, sanctions and integrity policies
5. Fit and proper assessmentPolicymakers and co-policymakers
6. Two day-to-day policymakersWorking from the Netherlands
7. Transparent control structureOwnership and control chart
8. Qualifying holdingsShareholders and declarations of no-objection
9. Securing funds of e-money usersSafeguarding method and documents
10. Minimum own funds and solvencyCapital deposit and own funds calculation
11. Liability insuranceCover 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 application process

  1. Confirm that the product issues e-money and that neither an exemption nor a payment institution licence is the better route. DNB and the AFM's joint InnovationHub can answer regulatory questions for new business models.
  2. Request a pre-application meeting, which DNB suggests for complex applications.
  3. Incorporate the Dutch company, recruit the two day-to-day policymakers and the supervisory board, and start the declaration of no-objection process for qualifying shareholders.
  4. Deposit the minimum capital and open the safeguarding account or obtain the bank's commitment letter.
  5. Prepare the application form, the SIRA, policies and annexes.
  6. Submit through DNB's Digital Supervision Portal, which requires an eHerkenning login.
  7. Phase 1: DNB checks completeness and generally requests missing information once. An application that remains incomplete may be dismissed, with the fee still payable.
  8. Phase 2: a DNB team assesses the application, may request more information or hold a meeting, and assesses the policymakers.
  9. DNB decides, enters the EMI in its public register and the EMI may start.
  10. Notify DNB before passporting into other EEA states.

How long it takes and what it costs

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.

ItemFigureSource
Statutory decision period3 months from a complete fileDNB
Submission to licence6 to 8 monthsFirm's planning figure
Licence application feeEUR 10,400Fee regulation, Article 5, row Wft.D1.05, in force since 22 September 2026
Annual supervision feeSet each year by DNBDNB

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.

Passporting across the EEA

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.

After authorisation, MiCA and PSD3

  • Prudential reporting to DNB on own funds and safeguarding, and annual audited financial statements.
  • Annual review of the SIRA and the recovery and exit plan.
  • Wwft obligations: customer due diligence and reporting unusual transactions to the Financial Intelligence Unit of the Netherlands.
  • DORA incident reporting and third-party oversight.
  • DNB fit and proper assessment of any new policymaker before appointment, and a declaration of no-objection for any new qualifying shareholder.

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.

Frequently asked questions

What is the minimum capital for an EMI in the Netherlands?

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.

How much does DNB charge for an EMI licence application?

EUR 10,400 under the fee regulation in force since 22 September 2026. An annual supervision fee applies once licensed.

How long does DNB take to decide an EMI application?

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.

Do the directors of a Dutch EMI have to be in the Netherlands?

Yes. DNB requires two day-to-day policymakers working from the Netherlands, and the management board must perform its work substantially from there.

What is a SIRA?

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.

Is there a small EMI exemption in the Netherlands?

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.

Can a Dutch EMI operate across the EU?

Yes. A licensed Dutch EMI can passport its services to every EEA state after notifying DNB.

Who supervises a Dutch EMI?

DNB grants the licence and supervises prudential and integrity matters. The AFM supervises conduct towards customers.

References

  1. DNB: Authorisation as an electronic money institution (overview)
  2. DNB: How long will it take to consider my application for authorisation?
  3. DNB: How to apply successfully
  4. DNB: Exemption from the authorisation requirement
  5. DNB: Notes to the EMI licence application form (PDF)
  6. Regulation on the financing of financial supervision, one-off actions (wetten.overheid.nl)
  7. Directive 2009/110/EC on electronic money institutions (EUR-Lex)
  8. Regulation (EU) 2022/2554 on digital operational resilience (DORA) (EUR-Lex)

About Buckingham Capital Consulting

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.