Netherlands DNB EMI and PI License in 2026: The Complete Guide
A 2026 deep dive into the Dutch EMI and PI licence: DNB authorisation with AFM supervision, EUR 125k-EUR 350k capital, a 3-month statutory decision period, two policymakers working from the Netherlands, a real Dutch office, and why the Netherlands became a top EU fintech hub.
Why the Netherlands became a top EU fintech jurisdiction
The De Nederlandsche Bank (DNB) is the Dutch central bank and the prudential supervisor for credit institutions, PIs, EMIs and insurance firms. The Authority for the Financial Markets (AFM) covers conduct and securities markets. For PIs and EMIs, DNB grants the licence and handles prudential supervision, which under PSD2 includes secure access to payment accounts and strong customer authentication. AFM supervises conduct: how PIs and EMIs treat their customers, including the information and rights PSD2 gives payment service users.
The Netherlands has attracted a growing cluster of EU-first fintechs (Adyen, Mollie, MoonPay Europe, Bitvavo, bunq, Nexi-NETS relocations). Four factors explain the pull: English-language procedure in practice, tier-1 supervisor reputation, deep banking and card-scheme ecosystem, and pragmatic digital-first regulatory approach.
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Capital, fees and scope
| Licence | Initial capital | Scope |
|---|---|---|
| Payment Institution (PI) | EUR 20k / 50k / 125k depending on services | PSD2 Annex I |
| Electronic Money Institution (EMI) | EUR 350k | PI services plus e-money issuance |
| Exempt small-scale PI (under EUR 3M/month) | Lighter rules, no EU passport | Domestic Dutch services only |
DNB charges supervision fees calibrated to firm size. There is also a one-time authorisation-fee range depending on licence type.
Process, timeline and substance
- InnovationHub engagement. Joint DNB-AFM hub for informal discussions on innovative models. Recommended.
- Incorporation. Dutch BV or NV with head office in the Netherlands. Evidence of paid-up initial capital goes in the file, for a company still being set up usually a bank statement or bank confirmation that the funds are deposited.
- File preparation. Business plan, programme of operations, governance, AML/CFT (aligned with Wet ter voorkoming van witwassen, Wwft), safeguarding plan, ICT and DORA, outsourcing register, fit-and-proper files.
- Submission. Electronic portal filing. English is widely accepted by DNB, though some forms remain Dutch.
- Completeness check. 2 to 4 weeks.
- Substantive assessment. The statutory decision period is 3 months from a complete application. The clock stops while DNB waits for extra information, and DNB itself says the full process usually takes longer than 3 months because the period only starts once the file is complete.
- Conditions precedent. Paid-up capital, safeguarding live, key hires on board.
Substance. Day-to-day management in the hands of at least two natural persons (policymakers) who work from the Netherlands, so the four-eyes principle holds locally. Both are screened by DNB for suitability and integrity. Physical Dutch office. Meaningful local staffing.
Ongoing supervision and PSD3 preparation
DNB runs risk-based supervision with onsite inspections every 2 to 4 years, quarterly prudential reporting, AML supervisory returns and DORA-aligned ICT oversight. Dutch PIs and EMIs migrate to the unified "payment institution authorised to issue e-money" under PSD3 in 2027. Verification of Payee (the IBAN-name check) has applied to euro-area PIs and EMIs since 9 October 2025 under the Instant Payments Regulation, for regular and instant credit transfers alike.
Ship a Dutch EMI or PI product with Crassula
Crassula Core keeps the ledger, client accounts with virtual IBANs, SEPA and SEPA Instant flows and the audit trail. Cards come through pre-integrated issuers you contract with directly, and identity checks run through connected verification providers. Transaction monitoring, sanctions screening, safeguarding and regulatory reporting to DNB stay with you and your chosen providers; Crassula supplies the ledger balances, transaction exports and, as your ICT provider, the incident and outsourcing information you need for DORA.
FAQ
DNB grants the licence and supervises prudential matters, including secure account access and strong customer authentication. AFM supervises conduct towards customers. A pre-filing InnovationHub engagement with both is recommended.
By law DNB decides within 3 months of receiving a complete application. The clock pauses while DNB waits for additional information, so the whole project, including preparation, usually runs longer.
PI EUR 20k/50k/125k depending on PSD2 services; EMI EUR 350k. You show it is paid up with the application, for example with a bank statement showing the deposit.
At least two natural-person day-to-day policymakers must work from the Netherlands; the rule is about where they work, not their residence. Both are screened by DNB on suitability and integrity. Physical Dutch office and meaningful local staffing required.
English is widely accepted by DNB for the substantive file; some statutory forms remain Dutch. Meetings typically in English.
Crassula Core runs the ledger, client accounts and IBANs, SEPA rails and the audit trail. Cards, identity checks, transaction monitoring and sanctions screening plug in through connected providers, and Crassula gives you the data and ICT-provider information for your safeguarding checks, DORA duties and reporting to DNB.
