Recovery & exit plans.
DNB requires payment and e-money institutions to maintain a recovery plan (returning to a healthy situation) and an exit plan (orderly wind-down). DNB’s good practices reveal recurring shortcomings — especially in scenarios, indicators and exit measures.
Status · last updated 7 October 2026.
What we do for you.
Three ways we help you with recovery and exit plans.
A recovery and exit plan in line with the DNB good practices: scenarios, indicators, measures and the feasibility of an orderly exit.
Assessment of your existing plan on the points DNB probes in practice, with concrete improvements.
Keeping the plan current with new products, growth or changed requirements, including the board discussion.
Frequently asked questions.
What is a recovery plan and what is an exit plan?
A recovery plan describes measures to return to a healthy situation after a serious disruption; an exit plan describes the orderly wind-down or termination. A combined plan improves coherence, provided the two purposes remain strictly separated with a clear transition from recovery to exit.
Which scenarios does DNB expect?
Both an internally driven scenario (incident: IT failure, fraud, failure of a major outsourcing partner) and an externally driven scenario (rising competition, falling demand). Describe the chain cause → effect → trigger value reached → plan activation. A good practice contains four scenarios, both qualitative and quantitative.
What often goes wrong with indicators?
Indicators are often not linked to an early-warning system with underlying thresholds and not quantified (‘a 20% decline’ — relative to what?). Good practice: indicators from multiple categories, with a substantiated choice and trigger value.
Where do exit measures fall short?
Common issues: underestimating the duration of a wind-down, repaying safeguarded funds and resolving payment blocks; exit costs and funding insufficiently worked out; assuming a single exit strategy. Good practice: multiple exit strategies (orderly wind-down, bankruptcy, sale).
Who must have a recovery and exit plan?
For payment and e-money institutions supervised by DNB — including as part of the licence application (guidance section 2.3) and ongoing supervision.
Which shortcomings did DNB identify in its review of exit plans?
In 2026 DNB identified five recurring gaps: outdated or incomplete plans, unrealistic timelines, overlooked dependencies on group entities and outsourcing partners, narrow scenario planning and underestimated exit costs. See the full analysis in our article “Wat verwacht DNB van herstel- en exitplannen van betaalinstellingen?” (in Dutch) under related articles.
How often must the recovery and exit plan be updated?
The plan must be kept current at all times: review it periodically and immediately upon material changes in activities, volumes, group structure or outsourcing. DNB also expects the current version to be uploaded in MyDNB, so it is available the moment it is needed.
How realistic do the timelines in an exit plan need to be?
More realistic than most institutions assume. Returning safeguarded customer funds takes long in practice — think of payment blocks, inactive customers and unreachable account holders — and the licence can only be surrendered once the last euro has been repaid. Timelines must be substantiated per scenario, not stated as one generic number of months.
Which costs must an exit plan cover?
Not just the direct wind-down costs. The ongoing operational costs during the wind-down period and the minimum capital requirements, which continue to apply until the licence is formally surrendered, must be budgeted and covered by sufficient available liquidity.
How should group and outsourcing dependencies feature in the plan?
Explicitly, per scenario. Problems at a parent company, group entity or critical outsourcing partner can directly affect the Dutch entity — precisely then the plan must be executable on a standalone basis, with own liquidity, own staff and enforceable contractual arrangements on continuity and data access.