TITLE: Netherlands' Central Bank Updates Guidance on Payment Services and E-Money Institution Licensing Applications
BODY:
On March 19, 2026, De Nederlandsche Bank (DNB), the Netherlands' central bank, published revised guidance accompanying application forms for payment services provider and e-money institution licences. The updated guidance aims to streamline the licensing procedure and reduce processing delays.
The key revisions clarify the two-phase licensing procedure and expand guidance on third-party fund safeguarding methods. The licensing process comprises: Phase 1, a completeness assessment where DNB verifies all required documentation has been submitted; and Phase 2, substantive review of application content including business setup, governance, and third-party fund safeguarding measures. DNB will only process complete applications. If an application is incomplete during Phase 1, applicants are typically requested once to provide missing documents. Should the application remain incomplete, Phase 2 will not commence and the application may be rejected, though applicable fees remain due.
The guidance significantly expands on third-party fund safeguarding, which requires payment service providers and e-money institutions to ensure customer funds are not commingled with company assets. Applicants may choose from three safeguarding methods: a dedicated foundation, a segregated account, or an insurance policy or guarantee. The revised guidance specifies required documentation for each method. For foundation and segregated account approaches, applicants must submit either proof of an opened bank account or a bank-signed commitment letter confirming customer acceptance procedures are complete and the account is opened and blocked until licence issuance.
DNB advises prospective applicants to thoroughly review the updated guidance and relevant website pages before submitting applications, verify all required documents are complete and current, and use the guidance as a checklist when preparing their dossier.
**Reference:** De Nederlandsche Bank (March 19, 2026). Herziene toelichting bij het aanvraagformulier voor een vergunning als betaaldienstverlener en elektronischgeldinstelling. Available at: dnb.nl