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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
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 and cryptoasset firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenMacmillan Cancer SupportRoyal College of MusicStaysureOval 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 to decision.

Day oneReady to trade

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

Your teamKey people in place

We assemble your team: two directors based in the Netherlands.

Same dayWritten proposal

The licence, the requirements, the cost and the timing for your business.

How we get you licensed and live

  1. Scoping and proposal. We confirm the permissions, the own funds under Methods D and B and the safeguarding route in a written proposal, and arrange an introductory meeting with DNB’s Expert Centre on Market Access 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, opened and blocked before the licence is granted, or a bank commitment letter, with the operating accounts opened alongside the application.
  4. Regulator engagement. DNB requests missing documents once, so every response we give is complete and on time, with your policymakers in post before filing and the declarations of no objection running in parallel within 62 business days, until the licence decision.

Your team, 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 peopleWe assemble your team: two directors based in the Netherlands.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, opened alongside the application.
TechnologyWhite-label technology for accounts, payments, wallets and card programmes, ready to go live with the licence.

One programme, from scoping to launch. Speak to an expert about this licence.

The licence in detail

Requirements, capital, timing, fees and common questions, drawn 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 submissionOur own figure, from the regulator’s published data and our applications

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes 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 feesFixedQuoted 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.

Your bank accounts

An EMI needs a safeguarding account, an operating account and settlement accounts in the currencies it serves. We open each alongside the application, so you trade from authorisation. See banking and payment processing.

Common questions

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; we plan 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 builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.

How we work.

  • Senior-ledThe same senior team handles your application from the first call to approval, including every question the regulator raises.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceDocuments, regulator questions, messages and progress in a shared client workspace, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have run regulated payment businesses, held regulator-approved roles and licensed payment firms in more than 60 countries since 2013.
  • One teamOne in-house team runs the whole programme, from the application to the day you go live.
  • ArrangedBank and safeguarding accounts, card issuing and payment processing, arranged directly through our relationships with banks, card schemes, issuers and processors.

Apply for this licence.

The licence, your team, banking and technology, delivered as one programme.