DNB payment statistics: Dutch PI and EMI reporting

DNB payment statistics are the one Dutch return a payment or e-money institution files under a European regulation with no Dutch statute in between. Regulation (EU) No 1409/2013 (ECB/2013/43), as amended by Regulation (EU) 2020/2011 (ECB/2020/59), sets the content. De Nederlandsche Bank turns it into three modules of its PAY taxonomy and runs them through Digitaal Loket Rapportages (DLR), on deadlines months ahead of the European ones. This guide covers the modules, the 2026 calendar, the derogation, the mechanics that get a file accepted, and the line between this return and the separate PSD2 fraud report.

1. Where the obligation comes from

Article 2 of the amended Regulation sets the reporting population as payment service providers, e-money issuers included, plus payment system operators. Article 3(1) sends each reporting agent to the national central bank of the member state where it is resident. Regulation (EU) 2020/2011 has applied since 1 January 2022 and is directly applicable, so no Dutch transposition is needed. DNB’s own submission calendar puts the Dutch obligation down to the ECB Regulation and its amendment, and to nothing else.

Other DNB statistics work differently. The balance-of-payments return, MESRAP, rests on the Wet financiële betrekkingen buitenland 1994 and applies only once DNB designates you. Payment statistics do not wait for a designation. If your licence classifies you as a payment service provider, you are in scope. When DNB launched PAY in 2021 it warned that the new Regulation removed some old exemption options, so more firms would report, and report more.

PAY replaced the older PMTS taxonomy after the 2021 reference periods. A procedure that still talks about PMTS-O or PMTS-G is out of date.

2. Who reports to DNB, and for what

Credit institutions, payment institutions and electronic money institutions resident in the Netherlands all report, including Dutch branches of institutions with a head office elsewhere. Annex I to the Regulation treats a branch as resident where it sits. So a Dutch branch reports to DNB, and a Dutch head office treats its branches in other euro-area states as residents of those states. Their activity goes to the host central banks, not into the Dutch return.

DNB’s quick reference guides handle two narrower activities separately:

• Account information services. An AISP reports its client numbers on T04.02, by each EEA country plus a rest-of-world total. Accounts accessed by AISPs are reported by the account-servicing provider. An AIS-only firm reports only T04.02.
• Payment initiation services. A PISP reports its initiation series on T01.02 (full) or T02.02 (derogation). The row “credit transfers initiated by a PISP” belongs to the account-servicing provider.

3. The three PSP modules

DNB maps the ECB’s Annex III tables onto three PSP modules. Payment system operators have their own: PAY-PSO-L, PAY-PSO-R and PAY-T2-NCB. The table numbers inside the modules are DNB’s own and do not match the ECB table numbers. Your field mapping should hold both.

The quarterly MCC breakdown on T06.02 excludes cards with an e-money function only. An unknown MCC goes to the “Missing” member, and T06.02 must still sum to the electronically initiated total on T06.01.

4. The 2026 calendar against the ECB ceiling

Article 6(2) requires each central bank to set reporting deadlines that let it meet its own transmission dates to the ECB. DNB’s version 1.0.0 calendar of 10 November 2025 covers December 2025 to December 2026:

DNB’s calendar says that where its dates differ from those shown against the obligation in DLR, the DLR dates apply. For PAY-D, two separate reports, one per half-year, are due on the same date. For the wider Dutch timetable, see the Dutch reporting calendar for a payment firm.

5. The derogation, and what it changes

Article 4 lets DNB grant a derogation, guided by proportionality, to three groups. A payment institution qualifies if it meets the conditions of Article 32(1) and (2) PSD2, including a monthly average of no more than EUR 3 million in payment transactions over the preceding 12 months, counting agents it is fully responsible for. An e-money institution qualifies if it meets Article 9(1) and (2) of Directive 2009/110/EC, including average outstanding e-money of no more than EUR 5 million. Other PSPs must meet both sets. Article 4(2) adds that this holds whether or not the firm is actually waived from prudential requirements under national law.

Meeting the conditions is not enough on its own. Under Article 4(3), DNB may grant a derogation only where all firms that could benefit together contribute no more than 5% at national level for each listed payment service and cumulatively, or no more than 5% of AIS clients. The reporting burden must also be disproportionate to the firm’s size. Under Article 4(5), DNB checks the conditions every year against the previous 12 months, and grants or withdraws derogations from the start of the second calendar year after that check. The ECB publishes the list of firms with a derogation.

A derogation is granted, never assumed. Losing one moves a firm from PAY-D to PAY-CQ and PAY-CH, which needs a full data build, so treat a withdrawal notice as a project trigger. See the ECB regulation guide for more on Article 4.

6. Filing in DLR: the rules that decide acceptance

Submissions go through Digitaal Loket Rapportages. DNB’s published instructions and the PAY 2.3.0 release notes of 30 June 2026 set the mechanics:

1. Access. You log in with eHerkenning. DNB’s PAY launch letter set a minimum of assurance level 3 and told firms to authorise named staff for the DNB reporting service in advance. If an external party files for you, you arrange its access yourself, because DNB will not.
2. Format. You can file in XBRL, or use DNB’s Excel template, which is converted to XBRL on receipt. For more than 100,000 data points DNB prefers XBRL, because it cannot guarantee processing via Excel. You may not change the template’s structure.
3. Taxonomy 2.3.0. Published 1 October 2026, it applies from the 2027 reference periods. It adds xBRL-CSV alongside xBRL-XML and moves to DPM 2.0 entry points. Excel filers must use the 2.3.0 template. xBRL-CSV files are checked against the EBA filing rules (EBA/XBRL/2026/02), and xBRL-XML files against DNB’s own filing rules.
4. Identity and values. The LEI in the file must match the one DNB holds. Values are in euro and cannot be negative. Wherever there are transactions, report both the number and the value.
5. Filing indicators. A table set to “negative” must carry no data, or the file is rejected. For a nil report, set every indicator but one to negative. In PAY-CQ, which has a single indicator, that indicator stays positive even though you report no data.
6. Open Z-axis limits. The Excel templates show a fixed number of country combinations: 239 in PAY-CQ and 62 in PAY-CH and PAY-D. A firm with a wide geographic footprint should file in XBRL.
7. Completion. You have met the obligation only once DLR shows the report as completed. An upload that failed validation does not count.

Sanctions are a European matter. DNB told reporters that, from 30 April 2024, payment statistics submissions fall under the ECB’s infringement framework: Regulation (EU) 2022/1917 (ECB/2022/31) and Decision (EU) 2022/1921 (ECB/2022/32). It covers the Annex IV minimum standards. The ECB has not published which elements it enforces.

7. PAY is not the PSD2 fraud report

Article 96(6) PSD2 requires PSPs to send their competent authority fraud statistics at least annually. That separate supervisory duty runs under EBA/GL/2018/05 (see our Article 96(6) guide), and DNB keeps its own template for it (version 1.4).

DNB’s fraud-reporting FAQ sets a six-monthly frequency for licensed PSPs with a registered office or branch in the Netherlands. PSPs exempted under Article 32 PSD2 and EMIs exempted under Article 9 EMD2 report once a year, broken into two half-years.

The two returns overlap on purpose. Regulation (EU) 2020/2011 defines fraudulent payment transactions and losses per liability bearer by reference to the EBA Guidelines. Its recitals say the fraud data in payment statistics should go beyond the EBA breakdown, by channel, scheme, cross-border card use and country, and that reporting frequency should match the EBA Guidelines. DNB publishes a mapping workbook between the PAY taxonomy and PSD2 fraud reporting. Build both from one fraud dataset, so that the PAY-CH fraud figures and the PSD2 figures for the same half-year agree.

8. Worked scenarios

Facts: A Dutch EMI issues debit cards on its e-money accounts and has no derogation. Rule: it files PAY-CQ quarterly and PAY-CH half-yearly. PAY-CQ needs card transactions by terminal country and an MCC breakdown on T06.02 for cards other than cards with an e-money function only. What the practitioner does: classifies the card product against the Annex II definitions, builds T06.01 and T06.02 from clearing data keyed on terminal country and MCC (using “Missing” only for real gaps), and ties quarterly sums to PAY-CH and PAY-CH fraud to the PSD2 template. Outcome: the Q3 2026 file reaches completed status before 30 October 2026, and the H2 2026 file before 31 March 2027, with no cross-return breaks.

Facts: A Dutch payment institution provides money remittance through agents in Belgium and Germany and has no branches. Rule: under Article 3(1), the resident institution reports to DNB. Annex I moves only branches to host residence, and an agent is not a branch. Article 32(1)(a) PSD2 counts transactions through agents the institution is fully responsible for towards the EUR 3 million test. What the practitioner does: reports agent transactions in the Dutch return with counterparty-country breakdowns, counts them in the derogation test, and confirms the treatment with DNB in writing, since the Regulation is silent on agents. Outcome: one Dutch return covers the whole network.

Facts: A small Dutch EMI averages well under EUR 5 million outstanding e-money. Rule: it meets the Article 9(1) EMD2 conditions, but only DNB can grant a derogation, after the Article 4(3) national 5% test and the Article 4(5) annual check. What the practitioner does: files PAY-CQ and PAY-CH until a derogation is confirmed. Once one is granted, it files two PAY-D reports by 31 March, one per half-year. It sets every unused filing indicator to negative and keeps the PSD2 fraud return on its own annual cycle. Outcome: the firm’s reporting load falls to one date a year, without a gap during the switch.

9. FAQ

10. What to do, today

• Head of regulatory reporting: put the DNB deadlines from the 2026 calendar into the reporting register, and check each one against the date DLR shows for the obligation.
• Reporting engineer: plan the move to PAY 2.3.0 for the 2027 reference periods, and decide between xBRL-XML and xBRL-CSV before the Q1 2027 file is due in April 2027.
• Fraud lead: reconcile the PAY-CH fraud figures with the PSD2 fraud template for the same half-year using DNB’s mapping workbook, and record any differences.
• Compliance officer: check whether your firm holds a derogation and whether it is on the ECB list, and file that evidence with the reporting procedure.
• Operations: check that eHerkenning authorisations for the DNB reporting service are current, have named back-ups, and are revoked when filers leave.

Related: ECB payment statistics regulation · NBB payment statistics in Belgium · Payment statistics in Spain · DNB statistical reporting