COREDO > Licensing > Financial Licences in the EU > EMI Licence in the Netherlands

EMI Licence in the Netherlands

The Netherlands is an EU and eurozone member state where the electronic money institution (EMI) licence is issued by the regulator De Nederlandsche Bank (DNB). With this licence, your company issues electronic money, operates clients’ payment accounts, and, through passporting, works across the entire EEA.

COREDO has supported financial licensing since 2016: we incorporate the Dutch B.V., prepare the complete application package and manage the dialogue with the regulators through to the licence being granted.

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Cost of the service
from EUR 77,500

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.

Electronic Money Issuance

You issue electronic money and build your own products on it: digital wallets, prepaid instruments, accounts holding client funds.

Payment Services under PSD2

The licence covers payment accounts, credit transfers, card payments, acquiring, issuance of payment instruments, money remittance, payment initiation and account information services. You choose the set of categories that fits your business model.

An EEA-Wide Passport

The Dutch licence lets you provide services in other EEA countries through branches or on a cross-border basis. You do not need a separate authorisation in each country: a notification procedure through DNB under EMD2 and PSD2 is enough.

Limits of the Licence

An EMI does not accept deposits or other repayable funds from the public — that remains the preserve of banks. Electronic money is issued by the institution itself, not by its agents. We check from the outset whether your model fits within these limits.

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.

Initial Capital from EUR 350,000

A full EMI licence requires initial capital of at least EUR 350,000 at the time the authorisation is granted. The application to DNB includes proof that the statutory minimum capital has been paid in. Afterwards, own funds may not fall below this amount or below a calculated requirement, which includes 2% of the average outstanding electronic money. Following its risk assessment, DNB may require up to 20% more. Capital is your company’s own funds, not part of the cost of COREDO’s services.

Client Fund Protection (Safeguarding)

Client money cannot be commingled with the company’s own funds: it is held in a separate account or protected by insurance or a guarantee. Funds received via a payment instrument, such as a card, must be safeguarded no later than five business days after the electronic money is issued. For the separate-account method, DNB has, since March 2026, expected proof of an opened account or a bank commitment letter confirming the account is opened and blocked until the licence is granted. Opening such an account usually takes the longest, so COREDO starts sourcing an EEA credit institution at the earliest stage. The company’s own funds need a separate operational account.

Management and Corporate Governance

DNB checks managers for fitness and propriety, assesses holders of qualifying holdings and the transparency of the structure. We describe the organisational structure and the key functions — risk management, compliance, internal control, technology, internal audit — and prepare managers for the assessment.

A Real Presence in the Netherlands

DNB expects the institution to have a real presence in the country and pays particular attention to this when reviewing the application. Together with you, we determine which functions and people will work from the Netherlands and reflect this in the programme of operations.

AML/CFT and the Responsible Person

An electronic money institution must counter money laundering and terrorist financing. COREDO prepares the AML/CFT policies, procedures and controls, as well as the documents on the qualifications, knowledge and experience of the responsible person.

IT, Outsourcing and Operational Resilience

DNB expects a detailed description of the ICT systems, critical functions, security measures, ICT contractors and incident-handling procedures. We prepare this documentation, the description of outsourcing, and the operational resilience and orderly wind-down plan.

Cost of COREDO Services: EMI Licence in the Netherlands

The cost of an EMI licence in the Netherlands consists of company incorporation and preparation of the application. Each part is priced separately, so you see in advance what you are paying for.

Service	Cost
B.V. incorporation (one individual shareholder and director)	EUR 2,500 + VAT
B.V. incorporation (corporate shareholder)	EUR 3,300 + VAT
Additional shareholder or director	EUR 250 + VAT per person
VAT registration (if required)	EUR 700 + VAT
Core application package: business plan and programme of operations, safeguarding model, corporate governance, AML/CFT, outsourcing, IT and cybersecurity, risk management, complaints handling	from EUR 50,000 to EUR 75,000 + VAT
Operational resilience and orderly wind-down plan	from EUR 7,500 to EUR 15,000 + VAT
FINREP Pro Forma: three-year financial projections in DNB format	from EUR 5,000 to EUR 12,500 + VAT
Responses to DNB and AFM queries and refinement after submission (on average three rounds)	from EUR 10,000 to EUR 20,000 + VAT
Project management and coordination	from EUR 5,000 to EUR 10,000 + VAT
Total for the EMI licence application, indicative	from EUR 77,500 to EUR 132,500 + VAT

B.V. incorporation includes preparing and filing documents with the Chamber of Commerce (KvK), the registered office, the tax number and coordination with the notary. VAT registration, if required, is a separate line in the table. Preparing the application includes all documents in the package, submission to DNB/AFM, all correspondence with the regulators during the review, and management of the project’s timeline.

Authority fees are not part of COREDO’s price: the client pays them separately, on top of our fees. For an EMI licence in the Netherlands, these are the KvK registration fee, the DNB fee for reviewing the licence application, and, after the licence is granted, the annual DNB and AFM supervisory fees. The amounts of the DNB and AFM fees are set by the Dutch regulation on financing financial supervision (Regeling bekostiging financieel toezicht).

Notary costs are not included in the price and are paid separately. On request, we can help with opening the safeguarding and operational accounts, professional indemnity insurance (PII), and ongoing accounting, bookkeeping and registered-office services.

The final cost depends on the complexity of your business model, the number of payment-service categories and the documents you already have: we give you a refined estimate after the initial consultation. The payment schedule is fixed in the service agreement.

Comparison with Other Licence Types in the Netherlands

Payment companies in the Netherlands choose between an EMI licence and a payment institution (PI) licence. The table below helps you see which fits your model.

Criterion	EMI Licence	Payment Institution (PI) Licence
What it gives	Electronic money issuance and payment services	Payment services without e-money issuance
Capital	Initial capital EUR 350,000 (EMD2, Art. 4)	Lower than EMI, depends on the set of payment services (PSD2, Art. 7)
EEA passport	Yes, under EMD2 and PSD2	Yes, under PSD2
Statutory decision period	3 months after DNB recognises the file as complete	3 months after receiving the application or all missing information (PSD2, Art. 12)
When to choose	Wallets, prepaid products, holding client funds as e-money	A model where you only process payments

If your model involves electronic wallets or client balances, you need an EMI licence specifically. Comparing EU countries? See also the EMI licence in Cyprus and the EMI licence in Latvia.

List of Documents for Obtaining an EMI Licence

For an EMI licence in the Netherlands, we need source documents and project details from you. Everything else — the business plan, policies, financial projections and DNB forms — COREDO prepares itself.

Owners, Directors and Key Persons

Passport or national ID of each director, shareholder and UBO

Proof of residential address for each director, shareholder and UBO, no older than 3 months

CV with education and professional experience of all proposed directors and key function holders

Information on any criminal, regulatory or legal proceedings involving directors and UBOs

For corporate shareholders — corporate documents and a full ownership chart

Documents on the source of funds and source of wealth of shareholders

Capital, Business Model and Accounts

Proof of the available initial capital

A detailed description of the business model and planned services

Information on the banks for the safeguarding and operational accounts, if already chosen

IT, Contractors and Internal Documents

Description of IT systems and third-party providers, if already chosen

Drafts of policies, procedures and contracts, if you have already prepared them

Other information and documents needed during the review

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).

01

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.

02

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.

03

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.

04

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.

05

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.

06

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.

Contact us

Our Experts

Head of Compliance

Pavel Kos

Head of Legal. Has been with COREDO since June 2017 and has headed the legal team since July 2020. Possesses extensive experience in supporting financial licensing projects in the Czech Republic and other EU jurisdictions.

Alena Mach

Executive Director

Nikita Veremeev

Founder & NED

Gregory Lutsenko

Head of Compliance

Frequently Asked Questions

When must the initial capital of EUR 350,000 be paid in?

The capital must be paid in before the application is submitted: DNB expects the package to include proof that the statutory minimum capital has already been paid in. Under EMD2, the capital must be in place at the time the licence is granted and must not fall below the minimum afterwards. For this reason, you should plan the company’s financing already at the document-preparation stage.

What happens if DNB considers the application incomplete?

DNB assesses only complete applications on their merits. Usually, the regulator requests the missing documents once; if the package is still incomplete after that, the application may be dismissed, and the review fee remains payable regardless. The statutory decision period is paused while DNB is waiting for your response. This is exactly why COREDO submits only a complete package.

Can I issue electronic money without a full licence?

In the Netherlands, there is an exemption regime for small issuers. Issuance under it is permitted only after entry in DNB’s public register, and the EEA passport is not available under this regime. If you plan to operate in other EU countries, you need the full EMI licence.

Do I need professional indemnity insurance (PII)?

Under PSD2, PII or a comparable guarantee is required if you provide payment initiation services or account information services. PII is not included in the price of COREDO’s services, but we help you arrange it on request.

What regulatory fees will I have to pay after the licence is granted?

After the licence is granted, the company pays annual DNB and AFM supervisory fees directly to the regulators, on top of COREDO’s price. The DNB fee consists of a base amount, a surcharge for the number of permitted payment services, and a variable component based on the company’s commission income. The amount of these fees for each year is set by the Dutch regulation on financing financial supervision, so we build them into the FINREP financial projections from the start.

Can I expand the list of services after the licence is granted?

Yes — for this, you submit an application to DNB to amend the licence. DNB charges a separate fee for reviewing it: the client pays it to the regulator directly, outside COREDO’s price, and the amount is set by the same supervision-financing regulation. The set of services affects the documents, the annual DNB fee and the preparation cost, so it is worth discussing expansion plans with us before the first submission.

Will the application be reviewed under the new PSD3 rules?

No. As of October 2026, PSD3 and the Payment Services Regulation have not yet been adopted, so an application submitted today is reviewed under EMD2, PSD2 and the Wft. The EU Anti-Money Laundering Authority (AMLA) has operated since 1 July 2025 and, from 2028, will begin direct supervision of a selected group of high-risk cross-border institutions.

Contact Us

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.

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