PI licence in the Netherlands — DNB
A PI licence in the Netherlands — a Payment Institution authorisation at DNB — covers PSD2 payment services without e-money issuance. The legal framework is the Wet op het financieel toezicht (Wft), transposing Directive (EU) 2015/2366, supplemented by DNB’s authorisation policy notices and the EBA Guidelines on authorisation. English-language files are accepted; substantive Dutch presence is required; the typical end-to-end timeline is six to nine months. This piece walks through the service catalogue, the capital floors, the lighter AIS registration path, what goes in the file, two worked examples, and how the PI track differs from the EMI track.
1. Who grants and who supervises
DNB is the competent authority for Payment Institutions (betaalinstellingen). It runs the authorisation, the prudential supervision and the integrity/AML framework supervision after grant. AML intelligence sits with FIU-Nederland, which receives unusual-transaction reports. Where the PI’s services touch investment products — for instance an AISP aggregating investment accounts — the AFM’s conduct perimeter interfaces. For most pure-payments applicants, DNB is the only counterpart during authorisation.
2. Legal basis
- Directive (EU) 2015/2366 (PSD2) — the EU framework
- Wet op het financieel toezicht (Wft) — Chapter 2 on betaalinstellingen, the licence requirement
- Besluit prudentiële regels Wft (Bpr) — the prudential decree
- DNB’s authorisation policy notices — the operational layer
- EBA Guidelines on authorisation under PSD2 — the checklist DNB assesses the file against
3. The eight PSD2 services in Dutch law
- Storten van contant geld op een betaalrekening — cash placement on a payment account
- Opnemen van contant geld van een betaalrekening — cash withdrawal
- Uitvoeren van betalingstransacties — execution of payment transactions (credit transfers, direct debits, card payments)
- Uitvoeren van betalingstransacties met een kredietlijn — execution with a credit line
- Uitgeven van betalingsinstrumenten of acquireren van betalingstransacties — issuing of payment instruments and/or acquiring
- Geldtransfers — money remittance
- Betalingsinitiatiediensten — payment initiation services (PIS)
- Rekeninginformatiediensten — account information services (AIS)
The selection is not cosmetic: it determines the capital floor, whether safeguarding applies, and which annexes DNB expects. Tick only what the business plan needs — each extra service adds review surface.
4. Capital floors by service
| Services applied for | Initial capital | Safeguarding of client funds |
|---|---|---|
| Service 6 only (money remittance) | €20,000 | Yes — PSD2 Article 10 |
| Service 7 (payment initiation) | €50,000 | No — PIS does not hold funds; professional indemnity insurance instead |
| Any of Services 1–5 | €125,000 | Yes — PSD2 Article 10 |
| Service 8 only (account information) | None — registration regime | No — AIS does not hold funds; professional indemnity insurance instead |
Ongoing own funds for institutions holding funds are computed under the PSD2 own-funds methods and can exceed the floor as volumes grow — the capital plan should show both numbers across the projection years.
5. AIS — the registration regime
A firm offering only Service 8 registers with DNB rather than obtaining a full authorisation. There is no capital floor; instead the firm carries professional indemnity insurance. The registration is published in DNB’s public register, and the conduct, security and — where in scope — AML obligations remain in full.
6. What goes in the application file
The file mirrors the EMI structure — see the EMI piece — with PI-specific differences:
- Programme of operations anchored to the exact Services 1–8 selection, with flows and settlement chains diagrammed
- Safeguarding under PSD2 Article 10 — segregated account at a credit institution or insurance/guarantee — for services where funds are held
- PIS-specific documentation where Service 7 is offered — SCA handling, dedicated-interface access, professional indemnity insurance
- AIS-specific documentation where Service 8 is offered — access-to-account mechanism, consent management, data minimisation
- Governance and fit-and-proper — day-to-day policymakers tested by DNB, with substantive presence in the Netherlands
- AML/CFT programme under the Wwft, including the FIU-Nederland reporting arrangements
- ICT/DORA framework and the outsourcing register
7. Two worked examples
Example A — remittance startup weighing scope.
Facts: a startup wants to offer money remittance (Service 6) to consumers, and is tempted to also tick Service 3 “to be safe” for future account-based transfers.
What the rule says: Service 6 alone carries a €20,000 floor; adding any of Services 1–5 lifts the floor to €125,000 and expands the safeguarding, own-funds and operational annexes to account-servicing scale.
What the practitioner does: licenses Service 6 only, with the business plan noting the possible later extension. A licence extension to DNB later is a bounded exercise; carrying an account-servicing file and capital from day one for a service that may never launch is not. Scope discipline shortens the review and the balance sheet.
Example B — PIS provider and the insurance question.
Facts: a checkout fintech applies for Service 7 only. It never holds customer funds; payments move directly from the payer’s bank to the merchant.
What the rule says: PIS carries a €50,000 initial capital floor and — because no funds are held — no Article 10 safeguarding. Instead PSD2 requires professional indemnity insurance or a comparable guarantee covering the provider’s liabilities from initiation activity.
What the practitioner does: procures the indemnity policy before filing and documents how the cover was sized against transaction volumes and liability exposure, following the EBA’s criteria. A file that says “insurance to be obtained at grant” invites a completeness finding; the policy term sheet belongs in the annexes.
8. The Reference Portal — mandatory if you issue Dutch IBANs
If the PI offers account servicing and issues Dutch IBANs, the Banking Information Reference Portal connection becomes mandatory. The connection runs through Betaalvereniging Nederland on a separate track with a meaningful timeline of its own — plan it in parallel with the licensing file, not after grant.
9. Realistic timing
The statutory review is thirteen weeks from a complete file — and completeness is where the time goes, because each substantive question round effectively restarts the practical clock. End-to-end with pre-application contact and feedback rounds: six to nine months for a well-prepared applicant.
10. What switches on at grant
- DNB DLR — the supervisory reporting channel
- DNB statistical reporting (BSI, MIR where applicable)
- FIU-Nederland unusual-transaction reporting through goAML
- Reference Portal connection (if Dutch IBANs are issued)
- CESOP reporting where cross-border thresholds are met
- IPR statistical report
- Conduct and complaints framework through Kifid / AFM
FAQ
Should I apply for a PI or an EMI?
If you issue electronic money — stored-value balances in the customer’s name — you need the EMI track. If you only provide payment services, the PI track is lighter. The choice is not reversible without re-licensing, so map the product roadmap first.
Can I file in English?
Yes — DNB accepts English-language files. Substantive presence in the Netherlands (management, decision-making, key functions) is still required.
How much capital does a Dutch PI need?
€20,000 for money remittance only, €50,000 for payment initiation, €125,000 where any of Services 1–5 are offered, and no capital floor for AIS-only registration. Ongoing own funds can exceed the floor as volumes grow.
Does the AIS registration regime mean lighter ICT obligations?
No. Registered AISPs carry the full PSD2 security requirements and DORA obligations where in scope. Capital is lighter; ICT is not.
What about PSD3 and the PSR?
The proposed merger of the EMI and PI categories will reshape this regime. Existing PSD2 authorisations are expected to be grandfathered with transitional provisions — track the PSD3 file.
How does DNB view fintech-bank stacks?
Recognised, with explicit expectations on accountability allocation between the partner institution and the fintech. DNB has issued sector guidance; the contractual allocation of AML obligations is a recurring inspection focus.
Is the Dutch PI licence passportable?
Yes. PSD2 passporting applies — the PI notifies DNB, which transmits the notification to host-state authorities for cross-border services or branches.
What to do, today
- CEO: choose the PSD2 services deliberately — the selection drives capital, safeguarding, insurance and AML scope. Engage DNB’s fintech contact point early.
- CFO: build the capital plan showing both the floor and the projected own-funds requirement year by year.
- COO: if you will issue Dutch IBANs, start the Reference Portal track in parallel with the licence file.
- MLRO: draft the AML risk assessment against the Wwft and set up the goAML reporting arrangements before grant.
- CTO: if AIS-only, plan against the registration regime — but budget for full ICT and DORA compliance regardless.
Related: EMI licence in the Netherlands · PI licence in Spain · CESOP reporting in the Netherlands · PSD3 tracker
