DNB · Netherlands

DNB public register (Art. 1:107 Wft): PSPs, EMIs, agents

Fintech Passport

October 27, 2026 · 11-min read

DNB public register (Art. 1:107 Wft): PSPs, EMIs, agents

The DNB public register under Article 1:107 Wft, the Openbaar Register, is where De Nederlandsche Bank publishes who may provide payment and e-money services in the Netherlands, on what basis, and from when. For a payment or e-money institution it is a working tool. It shows your own licence as the market sees it, every agent and passport you have notified, the EEA firms notified into the Netherlands, and the status of a counterparty you are about to onboard. This article covers using the register and keeping your entry right. It is not a licensing guide.

1. What the register is, in law

Article 1:107 Wft requires a public register, kept by the registerhouder and published on a website. The register must be set up so that anyone can read three things from an entry: from what date a firm may carry on which activities, any restrictions on those activities, and the member state of the firm’s seat.

The definition of registerhouder in Article 1:1 Wft splits the job. For the market-access sections covering payment service providers and e-money institutions, DNB is the registerhouder. The AFM keeps the register for the conduct-of-business parts of the Wft, such as financial service providers. A Dutch payment or e-money institution therefore has one register entry, and it is DNB’s.

Under Article 1:108 Wft, registered data stay open to free inspection for at least five years. An entry is evidence of a status; the licence decision, exemption or notification creates it.

2. Who is in the payment and e-money registers

Under Article 1:107(2) DNB must register without delay licensed firms, exempt firms that notified their intention to provide services, and firms entitled to operate from a Dutch branch or by providing services into the Netherlands. Article 1:107(3) adds agents (betaaldienstagenten) and branches. Point (n) covers agents and branches of payment institutions, and branches of Dutch e-money institutions providing payment services in another member state. Point (p) covers agents of Dutch e-money institutions.

DNB runs this as two sub-registers on dnb.nl: payment service providers and electronic money institutions. Each entry carries a registration type. The ones you will meet are:

Vergunning: a licence under Article 2:3a Wft (payment institutions) or Article 2:10a Wft (e-money institutions).
Vrijstelling: an exempt provider under Article 2:3d or 2:10d Wft. The entry carries DNB’s disclosure that the firm is not under DNB supervision.
Kennisgeving Agent NL: a Dutch agent of a Dutch principal.
Europees paspoort uitgaand: outbound passports of Dutch firms under Articles 2:106a and 2:107a Wft, listing cross-border services, EEA branches and EEA agents country by country.
Europees paspoort inkomend: EEA firms notified into the Netherlands under Articles 2:3e and 2:10e Wft, by cross-border services or a Dutch branch.
Kennisgeving: providers relying on the limited-network or electronic-communications exclusions in Article 1:5a(2)(k) and (l) Wft, who must notify DNB under Article 1:5a(3).

DNB’s CSV downloads of 27 October 2026 showed about 70 licensed payment institutions and about 30 licensed e-money institutions, against several hundred EEA firms notified in for cross-border services. Inbound passports are most of the register.

3. How to read an entry

Relation number DNB (relatienummer): DNB’s identifier for the firm, usually an R followed by digits. Store it and quote it to DNB; names change, the relation number does not.
Statutory name, trade names, seat: match all of them, not only the name in sales material.
Chamber of Commerce number and LEI: match on these, not on spelling.
Category: for example Betaalinstelling or Vrijgestelde betaaldienstverlener. Licensed and exempt providers are different counterparties.
Article, activity, country, date of entrance, end date: each permitted service is listed separately with its Wft article and start date; passport entries add the country.
Last update: the timestamp of the data you see.

Services follow the PSD2 Annex I numbering (for example 3a–3c, 5.1 issuing, 5.2 acquiring). The e-money register puts e-money issuing, distribution and redemption under 1.x and payment services under 2.x. Check that the service you contract for is listed, not just that the firm appears. The CSV’s irrevocability-date field reflects Article 1:107(4): on a strike-off, DNB records whether the decision can still be challenged.

4. Registering agents and when they may start

Under Article 2:3c Wft, a Dutch payment institution that intends to use an agent notifies DNB with the data set out in the implementing decree. DNB’s agent page refers to Article 42a of the Besluit markttoegang financiële ondernemingen Wft. DNB enters the agent once it has been able to verify that data, and informs the institution within two months of receiving it. If DNB cannot verify the data, it tells the institution as soon as possible. The institution may not provide services through the agent before the agent is registered. Article 2:3c(3) applies the same rule to Dutch e-money institutions that provide payment services through agents.

DNB’s guidance adds that the agent needs its own AML/CFT controls and its policymakers must meet integrity and suitability requirements; the notification, filed through MijnDNB, must show both.

For an agent or branch in another member state, Articles 2:106a and 2:107a Wft apply:

the institution notifies DNB;
DNB forwards the data to the host authority within one month;
DNB registers the agent or branch unless the host authority signals a suspected breach of law, including AML/CFT rules, and strikes an existing entry off on the same ground;
DNB decides within three months of a complete file;
the agent or branch may not provide payment services until registration is complete and DNB has been told the intended start date.

One detail of the register itself: the label DNB uses for Dutch agents of Dutch e-money institutions still cites Article 2:10c Wft. The official consolidated text shows that article repealed from 19 February 2019. The current legal basis is Article 2:3c(3).

5. Keeping your entry current

Because the register reflects what DNB has decided or been notified of, you correct it by notifying DNB. You never fix the register itself.

Agents and passports. Articles 2:106a(5) and 2:107a(5) apply the outbound procedure to any change in the notified data. A payment institution must also report the change without delay to the host authority, under Article 2:106a(5). The same logic applies to ending an agent: notify, then check the entry.
Organisation data. MijnDNB’s Toezicht organisatiegegevens service shows what DNB holds on you. Some fields you edit yourself; the rest you report through its feedback button. DNB has said it takes address data from the Chamber of Commerce.
Applications and notifications. These run through the MijnDNB service Toezicht aanvragen, with eHerkenning.

The Digitaal Loket Rapportages is for returns, not register changes.

6. DNB, AFM and the EBA register

Three registers get confused.

Register	Kept by	What it covers for payments	Use it to
DNB public register (Art. 1:107 Wft)	DNB as registerhouder	Licensed and exempt payment and e-money institutions, their agents and branches, outbound and inbound passports, Article 1:5a notifications	Verify a Dutch firm’s licence and services, its agents, and which EEA firms are notified into the Netherlands
AFM registers	AFM	Licences, notifications and exemptions under the AFM’s remit, such as financial service providers and investment firms. The AFM links to DNB’s register for other categories	Verify a firm whose activity is an AFM-registered one, such as credit or insurance intermediation
EBA central register (Art. 15 PSD2)	EBA, from national data	Payment and e-money institutions, exempt institutions, AISPs, agents, EEA branches and excluded service providers across the EEA	Cross-check an EEA firm and its agents abroad

The AFM’s role in payments is conduct supervision: Article 2:3e(5) and (6) Wft, for example, let it ask an EEA payment service provider for a central contact point and periodic reports. That does not move the register entry to the AFM. DNB’s e-money register page also says exempt e-money institutions fall under AFM rather than DNB supervision.

The EBA register rests on Article 15 PSD2 (Directive (EU) 2015/2366), Implementing Regulation (EU) 2019/410 and Delegated Regulation (EU) 2019/411. The EBA states that it has no legal effect: national authorities are responsible for the data and update it at least daily. Where DNB and the EBA disagree on a Dutch firm, DNB’s register is the national record.

7. Inbound EEA firms and their agents

An EEA payment service provider may operate in the Netherlands on its home licence under Article 2:3e Wft. It may do so from a Dutch branch, through an agent active in the Netherlands, or by providing services into the country. Article 2:3e(2) disapplies the Article 1:107(2) registration duty for these firms. DNB still lists the notified branches and cross-border services as inbound passports, and Article 2:10e Wft gives the e-money equivalent.

Agents are different. DNB states that agents active in the Netherlands for providers seated in another member state are registered in the home member state’s register and appear in the EBA register. The inbound categories in DNB’s downloads cover cross-border services and branches, not agents. If an EEA firm’s Dutch agent is missing from DNB’s register, that is expected. Verify the agent at home and on the EBA register.

8. Using the register for counterparty checks

DNB updates the register every business day at 06:00. It offers the full data as XML and CSV downloads per sub-register, and through an API. A sound check runs in this order:

Search by name. An asterisk works as a wildcard, and an empty search lists the whole register. Then confirm the relation number, KvK number and LEI against your onboarding file.
Read the category: licensed, exempt, agent, inbound passport or Article 1:5a notification.
Check each service you rely on and its start date, and for passports the country.
For an exempt firm, note DNB’s disclosure that it is not under DNB supervision.
For an EEA firm, verify on the home register and the EBA register.
For an agent, identify the principal and the services mandated.
Save the detail page or CSV row with the date; repeat at each periodic review.

9. Worked cases

A Dutch agent ready before the register

Facts: a Dutch payment institution signs a money-remittance agent with retail outlets and files the notification in MijnDNB. Three weeks later the agent wants to start.

What the rule says: under Article 2:3c(2) Wft DNB registers the agent once it has verified the data, within two months. The institution may not provide services through the agent before registration.

What the practitioner does: answers DNB’s questions quickly, keeps the agent’s system access off, and watches the register until the agent appears with service 6 listed.

Outcome: go-live follows the register entry, and the audit trail shows it.

An EEA EMI “licensed in the Netherlands”

Facts: a Dutch payment institution plans to use an EEA e-money institution as the e-money issuer in a co-branded card programme. The partner calls itself “licensed in the Netherlands”.

What the rule says: under Article 2:10e Wft the firm operates on its home licence after a home-authority notification. DNB lists that notification as an inbound passport. It does not license the firm.

What the practitioner does: finds the inbound entry in DNB’s e-money register, then confirms the licence on the home and EBA registers, recording all three checks with dates.

Outcome: the file shows a passported firm and names the supervisor that would act.

A stale outbound agent

Facts: a Dutch e-money institution ended an agent mandate in another member state six months ago. The agent still shows in DNB’s register under the outbound passport.

What the rule says: Article 2:107a(5) Wft applies the notification procedure to changes in the notified data. The register reflects what DNB has been told.

What the practitioner does: files the change through MijnDNB, attaches the termination date, and rechecks both DNB’s register and the EBA register until the entry changes.

Outcome: the public record stops showing an agent the institution no longer controls but would still answer for.

10. FAQ

Who keeps the register for Dutch payment and e-money institutions?

DNB, as registerhouder under Article 1:1 Wft for these market-access sections. The AFM keeps registers for its own categories.

How often is it updated?

Every business day at 06:00, according to DNB. Full XML and CSV downloads and an API are available.

What is a relatienummer?

DNB’s relation number for a firm, shown on every entry. It is the stable identifier to store and quote.

When may a Dutch agent start?

Only once DNB has registered it, under Article 2:3c Wft. Agents and branches abroad also need DNB to know the intended start date.

Are agents of EEA firms in DNB’s register?

DNB says they are registered in the home member state and shown in the EBA register. DNB lists the EEA firm’s inbound passport.

Are register changes made through DLR?

No. DLR is for reports. Notifications and organisation-data changes run through MijnDNB.

11. What to do, today

COO: pull your own entry and confirm the category, services, start dates and passport countries match your licence decision and notifications.
Agent network owner: gate every agent go-live on its appearance in DNB’s register, and reconcile your agent list against the CSV quarterly.
Head of partnerships: store relation numbers, KvK numbers and LEIs for every Dutch counterparty, and verify EEA firms on the home and EBA registers too.
MLRO: treat exempt entries as unsupervised by DNB and size due diligence accordingly.
Regulatory reporting: keep register changes in MijnDNB and returns in DLR, with named eHerkenning holders for each.