EMI Licence in the Netherlands, From Group Structure to DNB File

The three months run only from receipt of a complete application (art. 2:10b(4) Wft). DNB names two items as often missing: the safeguarding bank's commitment letter, or the opened account, and proof that the minimum capital is deposited. Missing items are generally requested once; after that the file may be dismissed, with the fees still due.

No. EUR 350,000 is the initial capital (art. 48(1)(n) Bpr). Once running, own funds are at least 2% of average outstanding e-money over the six preceding months. A new EMI holds the higher of 2% of outstanding e-money or its six-month target, and DNB may require up to 20% more (art. 64 Bpr).

No. Anyone seated outside the EU is barred from carrying on the EMI business in the Netherlands (art. 2:10f(1)(a) Wft). The licence sits in a Dutch legal person; the parent owns it and, like every direct or indirect holder at 10% or more, needs a declaration of no-objection, at EUR 7,300 each in 2026.

Yes. At least two natural persons determine day-to-day policy and carry out that work from the Netherlands (art. 3:15 Wft), and DNB asks whether the company has substantial presence and substance there. You recruit them; we prepare their fit and proper files. We never supply a director, a nominee or a general power of attorney.

In 2026: EUR 10,400 for the application (Wft.D1.05), EUR 2,900 per person for the fit test and EUR 1,600 for the proper test, and EUR 7,300 per qualifying-holder declaration of no-objection. The fees are due whether DNB grants or dismisses the application or the applicant withdraws. Our fee is on request.

By statute, DNB decides within three months of receiving the complete application (art. 2:10b(4) Wft). DNB's licensing guidance says total processing tends to take longer than three months, and it publishes no average. The time before the file is complete depends on the safeguarding bank and the declarations of no-objection, so we promise no duration.

For the account method of safeguarding, in practice yes. The designated account is held at a Dutch-seated licensed bank (art. 3:29aa(2) Wft), and the file carries the opened account or the bank's commitment letter, plus proof that the minimum capital is deposited. The statute's Dutch-bank rule concerns the safeguarding account, not the capital deposit.

An EMI issues e-money and may provide payment services; a payment institution provides payment services only. Initial capital is EUR 350,000 for an EMI, and EUR 20,000, 50,000 or 125,000 for a payment institution, depending on its services. The 2026 DNB application fee is EUR 10,400 for either. We set out the conditions for your model on a call.

Every direct or indirect holder of at least 10% of the capital or votes has a qualifying holding (art. 1:1 Wft) and needs a DNB declaration of no-objection (art. 3:95(1)(i)), at EUR 7,300 per holder in 2026 (Wft.D4.08). An intermediate holding and the owners above it both count. Holders below 10% fall outside the definition.

Yes, across the EEA, by passport. The EMI notifies DNB, which forwards the data to the host supervisor within one month (art. 2:107a Wft); a branch or agent abroad provides no payment services until it is registered. The passport is valid in EEA countries only, and exempt EMIs may not use it.

Yes. Under art. 48(1)(a) MiCAR an e-money token may be offered only by a credit institution or an electronic money institution, and art. 48(2) deems it electronic money. The issuer notifies its supervisor at least 40 working days before the offer (art. 48(6)); DNB charges EUR 4,800 for that notification in 2026.

The small-EMI exemption: at most EUR 150 per instrument or account at any time, no agents, and outstanding e-money liabilities not above EUR 5,000,000. An exempt EMI has no European passport, and DNB says exempt EMIs are not under its supervision. Whether your scheme fits is set out on a call.

No. An EMI issues e-money only at par value against the funds received, and grants no interest or other benefit tied to how long the holder keeps it (art. 4:31 Wft). When the holder asks, it redeems the e-money at par (art. 4:31a). The terms an EMI gives its customers have to carry both rules.

DNB may withdraw a licence that has not been used within twelve months of the grant, or where the business has stopped for more than six months (art. 1:104(1)(e) and (f) Wft). Since operations may start only after the grant, the launch plan and the licence date need to fit together.

Not yet. The Council and the European Parliament reached a provisional political agreement on PSD3 and the Payment Services Regulation on 27 November 2025, with technical work continuing before final adoption. Until the texts are adopted, PSD2, the second E-Money Directive and the Wft apply as described on this page.