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, 13-week statutory assessment, two local resident directors, 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 leads authorisation and prudential supervision; AFM supervises conduct and open-banking obligations.
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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Request demoCapital, 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 and capital paid up in a Dutch credit institution.
- 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. DNB targets 13 weeks from complete file. Real-world 6 to 10 months with RFI rounds, policymaker screening and optional onsite visit.
- Conditions precedent. Paid-up capital, safeguarding live, key hires on board.
Substance. At least two policymakers (directors) who are natural persons resident in the Netherlands, subject to DNB suitability and integrity screening. 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. For SEPA Instant IBAN-name check has been mandatory since 9 October 2025 under the Instant Payments Regulation.
Ship a Dutch EMI or PI product with Crassula
Crassula provides the core-banking platform aligned with DNB expectations: ledger, IBAN provisioning, card issuing, SEPA and SEPA Instant, KYC and AML (Wwft-aligned), safeguarding, DORA ICT and DNB-ready reporting.
FAQ
DNB leads authorisation and prudential supervision. AFM supervises conduct and open-banking obligations. A pre-filing InnovationHub engagement with both is recommended.
DNB targets 13 weeks from a complete file; real-world end-to-end 6 to 10 months including pre-application and conditions precedent.
PI EUR 20k/50k/125k depending on PSD2 services; EMI EUR 350k. Paid up in cash in a Dutch credit institution.
Yes. At least two natural-person policymakers resident in the Netherlands, 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 provides the core-banking platform aligned with DNB expectations: ledger, IBANs, cards, SEPA rails, Wwft-aligned KYC/AML, safeguarding, DORA ICT and DNB-ready reporting.
