Regulatory Framework: DNB, AFM, EMD2 and the Wft
An EMI licence in the Netherlands is issued under the national financial supervision act, which transposes the EU’s electronic-money and payment-services directives into national law. For your project, this means clear rules shared across the EU and two Dutch supervisory authorities.
De Nederlandsche Bank (DNB) issues the EMI licence and carries out prudential supervision: capital, own funds, client fund protection, assessment of managers. The application is submitted to DNB itself. Autoriteit Financiële Markten (AFM) supervises conduct of business — how your company deals with clients in the market.
Authorisation to operate the business of an electronic money institution is granted under Art. 2:10a of the financial supervision act — the Wet op het financieel toezicht (Wft). The European requirements for EMIs — initial capital, own funds, client fund protection and the EEA passport — are set by Directive 2009/110/EC (EMD2). Directive (EU) 2015/2366 (PSD2) defines the list of payment services you will be able to provide and the procedure for operating in other EEA countries.
Since 17 January 2025, Regulation (EU) 2022/2554 (DORA) has set requirements for digital operational resilience, IT risk and ICT contractors. Regulation (EU) 2024/1624 (AMLR) is the EU’s single anti-money-laundering rulebook: it applies from 10 July 2027, and electronic money institutions are among the obliged entities.
COREDO builds your application documents around these requirements from the outset: DNB sees one consistent logic across the business plan, the policies and the IT documentation, and you understand from day one the rules your company will operate under.
Licence Details: What an EMI Licence in the Netherlands Permits
A full EMI licence from DNB combines electronic money issuance and payment services in a single authorisation. Here is what it gives your business.
Requirements for Obtaining an EMI Licence in the Netherlands
DNB assesses the applicant on capital, client fund protection, management and internal processes. COREDO prepares the documents for each requirement and shows how your project meets it.
Procedure for Obtaining an EMI Licence in the Netherlands
The project follows clear stages, and at each one you know what is happening and who is responsible for the result.
Initial Consultation and Client Check
We go through your business model, the set of payment services and the documents you already have, then give you a refined cost estimate. Before work begins, COREDO carries out its standard client check (KYC/AML).
B.V. Company Incorporation (about 4 weeks)
COREDO prepares and files the documents with the Chamber of Commerce (KvK), arranges the registered office, the tax number and, if needed, VAT registration. A Dutch notary draws up the deed of incorporation with the articles of association, and we coordinate this work. The period runs from receipt of all required documents.
Preparing the EMI Licence Application (about 3–5 months)
We prepare the business plan and programme of operations, the safeguarding model, the corporate governance documents, the AML/CFT policies, the IT and outsourcing documentation, the operational resilience plan and the FINREP Pro Forma. The timeline depends on how complex the model is and how quickly you provide information.
Submitting the Complete Package to DNB/AFM
COREDO assembles the complete package and submits it to the regulator. The application is accompanied by proof of the capital paid in and details of the safeguarding account, and you pay the DNB review fee.
DNB's Review of the Application
DNB first checks the completeness of the package, then assesses the application on its merits. By law, the decision is made within three months of the file being recognised as complete; allowing for the completeness check and the regulator’s queries, we plan for about 5–6 months from submission of the complete package. COREDO prepares all responses and refinements — on average three rounds.
DNB's Decision and Market Entry
After a positive decision, the company receives the EMI licence and can start operating in the Netherlands. For services in other EEA countries, the company notifies DNB under the passporting procedure.
Indicative project timeline: about 9–12 months from the start of work — company incorporation about 4 weeks, application preparation about 3–5 months, review about 5–6 months.
Advantages of an EMI Licence in the Netherlands with COREDO
An EEA-wide passport.
A single DNB licence opens the market of every EEA country — through branches or cross-border, without a separate authorisation in each country.
A broad set of services in a single authorisation.
Electronic money issuance, payment accounts, transfers, cards, acquiring and payment initiation are covered by one licence.
An EU and eurozone country with clear taxes.
2026 corporate income tax rates are 19% and 25.8%, depending on the size of profit; the dividend tax rate is 15%.
A full cycle from B.V. to the licence.
COREDO has handled financial licensing since 2016: one team incorporates the company, prepares the application and manages the project’s timeline.
We take on the dialogue with the regulator.
We respond to DNB and AFM queries and prepare additional documents and updated materials for the whole review period.
A transparent, itemised estimate.
Incorporation, the core application package, the resilience plan, FINREP and post-submission support are priced separately — you see each part’s contribution.
Our Experts
Head of Compliance
Frequently Asked Questions
Ready to obtain an EMI licence in the Netherlands? Tell us about your business model and the services you plan to offer — after an initial consultation, COREDO will give you a refined cost estimate and project plan. We have supported financial licensing since 2016 and will take your company from B.V. incorporation through to DNB’s decision.