EMI licence in the NetherlandsOverview
Anyone issuing electronic money in the Netherlands must be authorised by DNB, registered by DNB as an exempt institution, or fall within a statutory exception. Authorisation is granted under the Financial Supervision Act (Wft), which transposes EMD2 and PSD2. DNB is responsible for prudential and integrity supervision, applying the Wwft and the Sanctions Act 1977, while the Dutch Authority for the Financial Markets (AFM) oversees conduct-of-business aspects. DNB and the AFM run a joint InnovationHub for questions on how the rules apply to new products.
DNB's assessment is notably thorough. Every policymaker, including management board members and, where applicable, supervisory board members, is screened for fitness, based on knowledge, skills and professional behaviour, and for propriety, covering criminal, financial, tax and supervisory antecedents. Day-to-day policymakers must work substantially from the Netherlands and their duties cannot be outsourced. Applicants must submit a systematic integrity risk analysis (SIRA) as a separate, verifiable document that quantifies gross and net risks across money laundering, terrorist financing, sanctions, conflicts of interest and fraud, together with a governance document describing how the SIRA is maintained.
The timetable is governed by a three-month statutory consideration period that begins only once DNB has confirmed in writing that the application is complete. DNB generally requests missing documents once and may dismiss an incomplete file, and the period is suspended while supplementary information, intake meetings or screening take place. The application fee is payable regardless of the outcome, including where an application is withdrawn.
Initial capital is EUR 350,000, with ongoing own funds calculated under the Wft and projected in the business plan for the current year and the following three. Safeguarding is commonly arranged through a separate customer accounts foundation (stichting derdengelden), whose management is screened as co-policymakers. Since 17 January 2025, ICT risk, outsourcing and incident reporting follow DORA, and PSD3 will in due course bring EMIs under the single payment institution licence with re-authorisation of existing firms.
Key benefits
- A highly regarded supervisor whose licence supports banking, card scheme and investor relationships
- EEA-wide passporting from a single authorisation
- Clear, published ten-step process and statutory decision period
- Joint DNB and AFM InnovationHub for early regulatory questions
- Strong talent pool in payments, risk and compliance in Amsterdam and beyond
- Established safeguarding model through a customer accounts foundation
Requirements
- Dutch legal entity with management board based substantially in the Netherlands
- At least two day-to-day policymakers, with any combined roles justified and conflicts mitigated
- Initial capital of EUR 350,000 and ongoing own funds in line with Wft rules
- Fitness and propriety of all policymakers and co-policymakers, assessed by DNB
- Declaration of no-objection for qualifying holdings in the institution
- Systematic integrity risk analysis (SIRA) reviewed at least annually
- Wwft-compliant customer due diligence, UBO verification, PEP and sanctions screening, transaction monitoring and reporting to FIU-Netherlands
- Safeguarding of e-money users' funds, typically through a customer accounts foundation
- Recovery and exit plan describing how third-party funds are returned
- DORA-compliant ICT, security and outsourcing arrangements
Licence options & capital
Full EMI authorisation
EUR 350,000 initial capital
E-money issuance with optional PSD2 payment services, passportable throughout the EEA, assessed within a three-month statutory period from a complete application.
Registration as an exempt EMI
DNB can register certain smaller e-money issuers as exempt institutions rather than authorising them. The scope is limited and must be confirmed with DNB for the specific model.
Passporting into the Netherlands
EMIs licensed in another EEA state may serve Dutch clients through a branch, agents or distributors following notification from their home regulator.
Step-by-step process
- 1
Readiness and InnovationHub
We test the model against Wft requirements and, where useful, raise interpretation questions with the DNB and AFM InnovationHub.
- 2
Entity, people and capital
The Dutch entity is incorporated, policymakers are appointed and capital and the safeguarding foundation are arranged.
- 3
Application file
The application form, business plan, SIRA, policies and policymaker screening forms are submitted through DNB's digital portal.
- 4
Completeness check
DNB reviews whether the file is complete and confirms in writing when the three-month statutory period starts.
- 5
Substantive assessment
DNB assesses all licensing requirements and screens policymakers, often including an intake meeting and supplementary questions.
- 6
Decision and launch
DNB grants the licence or communicates an intention to refuse; once authorised, passport notifications and reporting are set up.
Typical documents
- Certified copy of the notarial deed of incorporation and articles of association
- Business plan with programme of operations and three-year budget
- Funds flow chart and safeguarding arrangements
- Recovery and exit plan
- Risk analysis and risk management framework
- SIRA, its governance document, and integrity and sanctions policies
- Procedures manual, outsourcing policy and outsourcing risk analyses
- Security, privacy and data collection policies
- Organisation chart, remuneration policy and training programme
- External audit engagement and policymaker screening forms
How Legal Wealth helps
Legal Wealth supports clients who want the standing of a DNB licence and are prepared to meet its standards. We help shape the governance model, identify suitably experienced policymakers, coordinate the Dutch entity and customer accounts foundation, and prepare a SIRA and policy suite that reflect the actual business rather than templates. We manage DNB correspondence with discretion and plan for DORA, ongoing reporting and PSD3 re-authorisation. Contact info@legalwealthglobal.com for a confidential conversation.
Enquire with Legal WealthFrequently asked questions
How long does DNB take to decide?
The statutory consideration period is three months, but it only starts once DNB confirms in writing that the application is complete, and it is suspended during information requests and screening. Total project time is usually considerably longer.
Do directors have to live in the Netherlands?
Day-to-day policymakers must work substantially from the Netherlands, and their duties cannot be outsourced. DNB looks for genuine local management of the institution.
What is a SIRA?
A systematic integrity risk analysis is a structured, quantified assessment of the institution's exposure to money laundering, terrorist financing, sanctions breaches, conflicts of interest and fraud. DNB requires it as a separate document with defined governance and at least annual review.
How are client funds safeguarded?
Dutch EMIs commonly use a separate customer accounts foundation to hold users' funds, although other permitted methods exist. The foundation's management is treated as co-policymakers and screened by DNB.
Is there an application fee?
Yes. DNB charges a one-off fee, set by Dutch regulation, which is payable even if the application is withdrawn or refused, and an annual supervision fee once authorised.
Which supervisor handles conduct issues?
DNB handles prudential and integrity supervision; the AFM supervises conduct-of-business aspects such as customer information.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
