EMI and payment institution license in the Netherlands.
An electronic money institution license in the Netherlands — spelled “licence” in Dutch and EU legislation — is granted by De Nederlandsche Bank. Anyone wishing to provide payment services in the Netherlands (payment institution, PSD2) or issue electronic money (e-money institution, EMD2) needs a DNB authorisation. The application follows the eleven-chapter structure of the DNB Guidance, with the BMfo and Bpr as underlying rules. Below: the two tracks, capital, the MijnDNB procedure, the eleven chapters and the links with DORA, Wwft, the Sanctions Act and the fit-and-proper assessment.
Status · last updated 7 October 2026.
What we do for you.
Three ways we help you with the PSP/EMI licence.
Payment institution, EMI, exemption or agent: which route fits your proposition and what DNB expects.
The complete file in the eleven chapters of the DNB guidance: business plan, governance, SIRA, safeguarding, capital and recovery and exit plan.
DNB question rounds, fit-and-proper assessments and the transition to ongoing supervision.
Frequently asked questions.
How do I get an electronic money institution license in the Netherlands?
You apply to De Nederlandsche Bank. DNB tests the file against the eleven chapters of its Guidance: business plan, governance, capital, safeguarding, AML and sanctions controls, DORA and fit-and-proper testing of the board. Initial capital is EUR 350,000 for an e-money institution. In practice, reckon on six to twelve months from submission.
What are the two authorisation tracks?
Track 1 is the payment institution (PSP/PI): authorisation for one or more of the eight payment services in Annex I of PSD2, based on Wft Art. 2:3a, the BMfo, Bpr and PSD2. Track 2 is the e-money institution (EMI): authorisation to issue electronic money, based on Wft Art. 2:10a et seq., the BMfo, Bpr and EMD2. Both are supervised by DNB; an EMI may also provide payment services.
How much minimum capital is required?
For payment services initial capital depends on the service: EUR 20,000 (service 6, money remittance), EUR 50,000 (service 7, payment initiation/PIS) and EUR 125,000 (services 1–5). Service 8 (account information/AIS) has no minimum capital but requires professional indemnity insurance (PII). An e-money institution requires EUR 350,000. Besides initial capital, a continuous own-funds requirement applies.
How does the DNB application procedure work?
The application is submitted digitally via MijnDNB and has two phases. Phase 1 is the completeness check: DNB verifies that all annexes are present, with one opportunity to supplement within the set deadline (otherwise the application is set aside; fees remain payable). Phase 2 is the substantive assessment, including the fit-and-proper test of (co-)policymakers; supplements suspend the decision period. The statutory decision period is three months after a complete application; in practice a process takes six to eighteen months.
What are the eleven chapters of the application?
(1) General information, (2) Business case (business plan, flow chart, recovery/exit plan), (3) Controlled operations, (4) Sound/ethical operations (SIRA, CDD, Sanctions Act, transaction monitoring), (5) Suitability and integrity of directors, (6) Four-eyes principle (two day-to-day policymakers), (7) Transparent control structure, (8) Qualifying holding (declaration of no objection), (9) Safeguarding of client funds, (10) Own funds and solvency, and (11) Professional indemnity insurance (services 7/8 only).
What does safeguarding of client funds involve?
Payment and e-money institutions must safeguard received client funds so that, on insolvency, they fall outside the estate. The basis is Wft Art. 3:29a–c, Bpr 26e/26j, PSD2 Art. 10 and EMD2 Art. 7. In practice this is done via a segregated client-funds account or an equivalent guarantee/insurance. For PSPs this is separate from any MiFID client assets (in dual-track applications).
How does DORA feed into the application?
DORA (Regulation (EU) 2022/2554) has been the primary framework for ICT risk management since 17 January 2025 and feeds into Chapter 3 (controlled operations). DORA effectively replaces the earlier EBA guidelines on ICT and outsourcing for the financial sector. Applications still written in the older EBA vocabulary must be updated to the DORA requirements (ICT risk-management framework, incident reporting, third-party register).
Is there a lighter regime for small parties?
For payment institutions there is no light authorisation regime below a threshold: all PSPs requiring a licence go through the same Guidance. What differs is the level of detail DNB finds proportionate. For very small parties the Wft Exemption Regulation may help (registration instead of a licence, limited governance requirements). For e-money there is a lighter alternative: the regime for small e-money institutions via exemption.
What changes with PSD3 and the PSR for authorisations?
PSD3 (directive) and PSR (regulation) will replace PSD2. PSP authorisation will materially fall under the PSR and the EMI regime will be absorbed into a broader PSP/EMI framework. The application date is not yet final. For pending applications the current PSD2 framework continues to apply until the application date; for new applications we factor in the transition. See also our PSD3 & PSR knowledge area.
How long does a DNB licensing process take in practice?
The statutory decision period is three months after a complete application, but the clock stops every time DNB asks follow-up questions. In practice, count on six to twelve months from filing, heavily dependent on the quality and consistency of the file — plus the preparation time before that. A file that is complete and consistent in one pass pays for itself in lead time.
Should I still apply for a PSD2 licence now or wait for PSD3?
Do not wait. A PSD2 licence obtained now remains valid for up to 27 months after PSD3 enters into force through grandfathering, provided re-authorisation is applied for in time — and waiting costs market access. What is smart: structure the file along PSD3 lines already (including the merged PI/EMI category), so the re-authorisation later becomes an update rather than a rebuild.