01
The perimeter starts with a product map
Money receipt and transfer, acquiring, payment initiation, account information, e-money issuance, wallets, cards and exchange are mapped by contract, participant and possession of funds. A technology interface does not avoid licensing where the company actually provides a payment service.
02
PI and EMI permissions support different models
A payment institution is authorised for specified payment services, while an EMI issues electronic money and may provide authorised payment functions. A client balance, redemption, stored-value duration and the user agreement often determine classification.
A Dutch payments project first classifies every service and money flow, then selects a PI, EMI, exclusion, exemption, agent or another lawful operating model.
03
DNB tests completeness before substance
The application is filed through the supervisory portal and checked for completeness before substantive assessment. The business plan, programme of operations, financial model, capital, safeguarding, governance, fitness, AML, IT, security, outsourcing and wind-down must describe one functioning system.
04
Safeguarding and capital require evidence
The client-funds protection model, segregated account or other permitted arrangement is aligned with the actual funds flow. DNB lists proof of an opened safeguarding account or bank commitment letter and deposited minimum capital among documents whose absence can delay the file.
05
Governance, AML and IT must operate before authorisation
Day-to-day policymakers and key function holders are appointed in time and assessed. Risk, compliance, internal audit where relevant, Wwft/KYC, sanctions, transaction monitoring, incident handling, cyber security, data, outsourcing and continuity are evidenced by policies, systems and accountable people.
06
Passporting does not replace home authorisation
Once authorised, the institution may use the EEA notification route for other states, but services, agents, branches and host rules are assessed separately. Model changes and material outsourcing are handled before implementation, and status is checked in DNB's public register.
FAQ
Frequently asked questions
Who grants a PI or EMI licence?
De Nederlandsche Bank is the Dutch prudential supervisor and licensing authority.
Can an incomplete application be supplemented later?
DNB checks completeness before substantive review; an incomplete file may be set aside while the fee remains due.
Does the licence cover the entire EEA?
It may support passporting through the notification process, but services and host-state rules must be checked separately.
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