All companies conducting payment services in the Netherlands must have a license from DNB or be exempted or exempt from the licensing requirement. This is regulated through the Payment Services Directive (2015/2366/EU), also known as the PSD2 directive. Payment service activities can only be started after obtaining a DNB license or after registration in the register as an exempted payment service provider, unless a legal exception to the licensing requirement applies. PSD2 has significant implications for anyone providing or intending to provide payment services. On this DNB page, you can find information for financial parties dealing with PSD2. In te course of 2024 a licence is also required for crypto services. You can read more about the crypto services licence here.

Licensing requirement for payment services in the Netherlands

PSD2 has introduced two new payment services: initiation of (internet) payments (payment initiation services) and provision of consolidated information on (online) payment accounts (account information services). PSD2 obliges banks to grant access to these new service providers, based on the consent of their customers, to the payment accounts of those customers. Existing companies providing payment services at the introduction of PSD2 rules must also comply with DNB’s new obligations, and they need to apply for a license. PSD2 establishes new rules for controlled and sound business operations. It also introduces new obligations for license holders. Additionally, certain shareholders of license holders must have a declaration of no objection (vvgb). The Financial Markets Authority (AFM) oversees the information provision of payment service providers and ensures how they handle their customers. Payment service providers with licenses are registered in the register of licenses.

Payment services requiring a PSD2 license from DNB

1. Services enabling the placing of cash on a payment account held by the payment service provider, and all transactions required for operating a payment account.
2. Services executing payment transactions, including money transfers, on a payment account at the user’s payment service provider or at another payment service provider.
3. Services enabling the withdrawal of cash from a payment account, and all transactions required for managing a payment account.
4. Services executing payment transactions where the funds are covered by a credit line provided to the payment service user.
5. Services issuing payment instruments and/or accepting payment transactions.
6. Money transfers.
7. Payment initiation services.
8. Account information services.

Applying for a PSD2 license for payment services at DNB

You can submit an application for a license to provide payment services to DNB. The application must be made through the application form in the Digital Supervision Desk. Here is a link to the Digital Supervision Desk and the explanation of the application form. DNB’s license application process follows a step-by-step plan. Various steps are taken during the license application, and sometimes answering questions may arise. Therefore, we assist clients with the payment services license application. DNB may also request additional information, leading to a suspension of the decision period. DNB may engage in a conversation with the license applicant, and the integrity of your company’s policy makers will be assessed.

Payment services not requiring a license

For certain activities, no license is required, but there may be a registration obligation, such as for limited networks, or a notification obligation, such as for telecommunications services.

1. Services involving only physical or paper currency, or paper checks, bills of exchange, or similar payment instruments.
2. Payment services where no direct end users are involved or payment services that are intra-group.
3. Payment transactions carried out through a trade agent acting on behalf of the payer.
4. Services related to securities (for which different licensing requirements apply).
5. Technical service providers supporting payment services.
6. Service providers performing payment transactions via telecommunications and information technology.

Notification obligation for facilitating payment services in the Netherlands

If you are a provider of an electronic telecommunication network and you facilitate payment transactions for the purchase of digital or voice-activated services billed (for example, a subscription for a music streaming service), this activity must be reported to DNB, regardless of the transaction volume. The payment transactions under this service must remain within the above-mentioned (transaction) limits. You can make a notification here through the Supervision service.

Blenheim’s license specialists guide clients through the necessary licensing procedures at DNB and AFM.
Feel free to discuss your business services with us.