EMI license in Netherlands

Due to the competitive nature of the Dutch economy, foreign businesses find it a welcoming, stable and rewarding place to invest. Compared to other nations, the Netherlands’ GDP per capita is higher than the EU average.

Throughout history, the Dutch economy has proven itself to be one of the most powerful economies in the world.

A number of international rankings rank the Dutch as one of the most competitive economies in Europe, the fourth most competitive nation in the 2020 IMD rankings, and the fifth most innovative nation in the 2020 Global Innovation Index, according to the World Economic Forum.

Climate of competition for businesses

Incentives from the government are often offered to companies operating in a competitive environment, especially to innovators.

A multilingual workforce with a high level of education and an open mindset provide the basis for these fiscal endeavors.

In addition to welcoming internationals living in the Netherlands, the country’s Expat Centers also contribute to the success of its economy through the creation of a dynamic and diverse workforce.

Infrastructural advancements

From a geographical perspective, the Netherlands makes sense. In just 24 hours, Amsterdam and Rotterdam can reach 95% of the world’s most lucrative markets. There are efficient airports, railways, waterways, and ports connecting the Netherlands domestically and internationally.

Innovative and future-proof

Unrivaled entrepreneurial spirit is fostered in the Netherlands. A strong Dutch economy is attracted to the world’s leading companies because it embraces innovation, sustainability, and digitalization. From agrifood and financial services to quantum technology, companies look to the Netherlands for partnerships between the public and private sectors.

A nod to the nation’s future-oriented thinking was highlighted by the EU Innovation Scoreboard 2022, which ranked the Netherlands fourth for innovators.

2022 marks the second consecutive year in which the Dutch economy has grown by 4.5 percent, following a growth of 4.9 percent in 2021. Such growth over two consecutive years had not yet been recorded this century.

There was a record high inflation rate and a record high household consumption rate. An annual review of the economy for 2022 has been released by Statistics Netherlands (CBS).

Since March 2022, Coronavirus has been eradicated from the landscape. Russian invasion of Ukraine disrupted the Dutch economy at the end of February. As a result, inflation soared rapidly. The housing market remained strong despite a rise in prices (adjusted for inflation).

There has been a marked increase in the number of EMI (E-money Institution) permits received by the Netherlands in recent years. The Netherlands offers fintech foundations looking to operate in the payment options industry with a range of opportunities due to its robust regulatory framework, favorable conditions for international teams, and efficient licensing process.

In terms of issuing licenses for payment institutions (PI) and e-money institutions (EMI), De Nederlandsche Bank (DNB) is one of the most proactive entities in the European Economic Area (EEA).

De Nederlandsche Bank (DNB), the Dutch regulator, is notable for issuing licenses faster than many European jurisdictions, where obtaining one typically takes between 12 and 15 months.

The concept of EMI

EMI license in Netherlands

A prepaid card is a form of electronic money, also called e-money, and EMIs issue prepaid cards, electronic wallets, and other types of electronic money for individuals and businesses.

Disbursing e-money is the responsibility of a legal entity.

A claim on the issuer representing electronic money is defined as a monetary value that is electronically stored, including magnetically, and is issued upon receiving funds in order to make a payment transaction, and which is accepted by a natural or legal person other than the electronic money issuer.

An e-money system is a way to store currency in bank computers backed by fiat currency. The electronic equivalent of cash is, to put it simply, an electronic payment system.

EMI license definition

It is a license for releasing electronic money that is known as the EMI (Electronic Money Institution).

Through this method, companies can perform quasi-cash operations like topping up electronic wallets, purchasing virtual currency, and making payments to forex accounts. As well as that, the license enables your business to be an EMI institution-a company that can issue digital currencies to both individuals and legal entities.

The creation of a virtual currency wallet, third-party payment service, and other resources requiring virtual currency would be impossible without an electronic money institution.

E-money cannot, however, be issued by PIs (Payment Institutions). Electronic Money Institutions and Payment Institutions differ primarily in their ability to issue e-money.

The contrasting legal treatment of payment accounts provided by PIs and EMIs results in the adoption of different business models by these institutions. An EMI license in 2023 can be obtained from one of several jurisdictions, as discussed in this article.

A potential risk associated with the provision of financial services has prompted governments to implement laws and regulations to protect consumers.

The respective governments in the regions where companies wish to operate set specific standards that have to be met by companies offering financial services.

In some jurisdictions, the EMI license is issued by a different regulatory body. Regulatory bodies in their chosen jurisdiction require businesses to research and comply with specific requirements before they can submit their applications.

Aspects to consider

  • In the Netherlands, EMI licenses are relatively easy to obtain due to the short licensing process. De Nederlandsche Bank (DNB), the Dutch regulator, issues licenses within the realistic timeframe of 9 months, although some cases are completed within 6 months, while most European regulators require 12 to 15 months. In addition to offering companies a faster route to market entry, this expedited process allows them to capitalize on emerging opportunities sooner.
  • Openness to International Teams: The Netherlands provides flexibility when it comes to local presence demands for international teams. Dutch regulators do not require a significant local presence, unlike many other agencies. Just two local directors are needed for an application, allowing the majority of the team to be from another European country. The Netherlands offers fintech firms a favorable regulatory environment that facilitates global collaboration and allows them to leverage diverse talent pools.
  • Documentation in English: One of the advantages of pursuing an EMI license in the Netherlands is the possibility of submitting most authorizing documents in English. The Netherlands accepts English documentation rather than local language documentation, which reduces the burden and cost associated with translations. With this flexibility, international applicants are able to appeal more efficiently.


An E-money EMI / Electronic Money Institution may perform the following activities under Section 3:34 of the Financial Supervision Act:

  1. Issue electronic money and provide services related to it;
  2. Provide other payment methods and manage them
  3. Accounts for making payments. Users can deposit and withdraw cash from such accounts, use account cards to purchase goods and services, and place and withdraw cash. Funds can also be transferred as well as direct debits set up.
  4. Services provided by merchants. Merchant services can be provided by holders of a license issued by a payment institution. The company can act as a master merchant and accept payments from merchants using credit cards.
  5. Remittance of funds. A payment institution can also provide money remittance or transfer services. International cross-border payments can be made through this service by the payment service provider.
  6. Services for initiating payments. This model allows an initiator to initiate payments directly from the user’s bank account, subject to the user’s consent, removing Visa and Mastercard networks from the payment process. A payment service provider who holds a payment institution license is able to initiate payments directly from the user’s bank account and transfer the amount directly to a merchant retailer’s bank account.
  7. Information about your account. This permission enables payment service providers to view consolidated accounts information in one place, subject to the user’s consent.

How Are EMI and PI Accounts Different?

In spite of what many customers may think, PIs and EMIs are distinct from bank accounts.

In order to assess account functionality, let us examine the kind of institution that offers these accounts.

Because PI accounts cannot hold money on behalf of their users, they are more limited than EMI accounts.

  • It is expected that PI funds will be spent, transferred, or withdrawn relatively quickly after entering an account.
  • As opposed to the EMI license, which allows users to open e-wallets and make purchases online, withdraw money, and pay bills, users of the EMI license can open e-wallets.

Capital requirements for establishing each institution also vary significantly because of these significant differences in functionality.

How to get an EMI license in the Netherlands


EMI license in Netherlands According to the Dutch regulator, De Nederlandsche Bank (DNB), getting an EMI (E-money Institution) permit requires you to meet certain requirements.

Payment service providers must comply with these requirements in order to maintain a system of fair and honest money.

A Dutch EMI permit can be obtained by filling out the following requests:

  • In order to conduct payment services activities in the Netherlands, applicants need to create a legal entity.
  • A minimum fund demand must be met by the applicant. In the Netherlands, an EMI permit requires a minimum of €350,000 in authorized funds.
  • It determines whether the applicant company’s key employees are a good fit and proper fit. In order to fulfill their roles effectively, these individuals must possess the required qualifications, experience, and integrity.
  • In addition to their business plans, applicants must submit a marketing strategy and risk management plan. As part of the commerce plan, the proposed commerce model should be demonstrated as viable and sustainable.
  • In addition to an organizational structure, the applicant must have a management team that supervises the EMI’s operations and compliance. A DNB evaluation will determine whether the proposed organizational structure is adequate and effective for ensuring proper governance and risk management.
  • Applicants are required to develop robust operational plans, including risk management frameworks, inside control instruments, and compliance methods. Monitoring and managing payment options risks should be demonstrated by these methods.
  • Measures to prevent the misuse of services for illicit activities should be established by the applicant based on Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) regulations. Among these activities are conducting due diligence on the customer, monitoring transactions on an ongoing basis, and reporting suspicious activities to the appropriate authorities.
  • In order to keep customer data safe, ensure secure transactions, and protect against cybersecurity threats, the applicant must have robust IT systems and safety measures in place.
  • DNB’s governing requirements for reporting and record keeping require applicants to establish comprehensive procedures. The goal is to routinely report financial data, transaction data, and other operational data that are relevant to the business.
  • In order to maintain compliance with the DNB’s regulations, EMI holders must maintain continuous compliance once licensed. AML/CFT compliance, compliance with regulatory inspections, and cooperation with regulatory audits are all part of this.

The DNB’s official guidelines and regulations are the most current source of information regarding EMI permits, and companies need to consult them for the most accurate information.

We can also provide valuable guidance throughout the licensing process by engaging the services of our professional legal and regulatory advisors who are familiar with the Dutch regulatory landscape.

As an EMI/EMI authorized in the Netherlands, you can provide your services as a provider of electronic money services to all member countries of the European Economic Area without having to obtain additional licenses.

In the European Economic Area, there are Austria, Belgium, Bulgaria, Croatia, Cyprus (Republic of), the Czech Republic, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden.

Required information

You will be required to submit the following information with your E-money EMI / Electronic Money Institution license application:

  1. Details about the company
  2. The operational plan
  3. A financial forecast and a business plan
  4. Describe the structure of your business
  5. A copy of your initial capital investment
  6. Information regarding the safeguarding of client funds
  7. Governance and compliance arrangements
  8. Complaints and security incidents must be monitored, handled, and followed up according to the security incident procedure
  9. Information about how sensitive payment data is filed, monitored, tracked, and restricted
  10. Recovery and continuity measures for businesses
  11. Gathering statistical data about transactions, fraud, and performance
  12. Information security policy
  13. Controls to manage your AML/CTF requirements, including risk assessment and mitigation measures
  14. Information on shareholders
  15. Arrangements for outsourcing


A complete application must be decided within three months of receipt by the Dutch regulator. To obtain the license, it usually takes about five to six months.

Considerations to keep in mind

Under the governing framework, Payment Institutions (PIs) are permitted to achieve broader capabilities. A Dutch PI permit holder can suggest to end users the option of storing funds in their electronic wallets for longer periods of time, unlike other authorities that strictly differentiate between PI and EMI licenses.

It further reinforces the Netherlands’ position as a forward-thinking hub for fintech by giving fintech companies the ability to provide innovative computerized banking decisions.

Dutch regulators place a great deal of emphasis on Anti-Money Laundering (AML) procedures and expect complete compliance with AML-specific requirements. DNB standards are known for their high standards in this area, although it is not unique to the Netherlands.

In order to receive an EMI grant, fintech firms should demonstrate that they have a thorough knowledge of AML rules and procedures for mitigating risks related to them. Dutch financial system integrity and respectability are enhanced by the stringent AML measures implemented by the DNB.

The Netherlands may be costly when it comes to doing business, including factors like employee salaries, office rent, and legal fees. It is however possible to mitigate costs by maintaining a compact central office and allocating expenses strategically across multiple authorities given the lower demand for a local presence.

Having a good balance between costs and profits is imperative for companies looking to establish a strong presence in the European fintech market.

​​An EMI license is crucial to the success of your business. Our team at Regulated United Europe can assist you in incorporating a company and applying for an EMI license. It’s not an easy task, so make sure you get legal assistance.

With the help of experienced lawyers, business development specialists, and financial accountants, you can establish EMI business in the Netherlands quickly, easily, and transparently.

Contact us for a personalized EMI license consultation now to set the stage for long-lasting success.


“Are you considering launching your EMI business in the Netherlands? This could be the perfect fit for you. Reach out to me today, and let’s delve into a comprehensive discussion about your project.”

Milana Scherbakova


phone1+370 661 75988
email2[email protected]


The Dutch economy is highly competitive, making it an attractive place to invest for foreign businesses. Dutch GDP per capita is higher than the average of all member states of the EU.

A strong economy like the Dutch has been a hallmark of the Dutch economy throughout history.

Global Innovation Index, according to the World Economic Forum, ranks the Dutch as the fifth most innovative nation and fourth most competitive economy in Europe. The IMD rankings place the Netherlands as the fourth most competitive nation in Europe.

In recent years, the Netherlands has received an increasing number of EMI (E-money Institution) permits. Due to its robust regulatory framework, favorable conditions for international teams, and efficient licensing process, the Netherlands offers fintech foundations looking to enter the payment options industry with a range of opportunities.

In the European Economic Area (EEA), De Nederlandsche Bank (DNB) is one of the most proactive entities in regards to licensing payment institutions (PI) and e-money institutions (EMI). It is notable that the Dutch regulator, De Nederlandsche Bank (DNB), issues licenses more rapidly than most European countries, where licenses typically take 12 to 15 months to obtain.

For individuals and businesses, prepaid cards and electronic wallets are forms of electronic money, also called e-money. A legal entity is responsible for disbursing e-money.

Electronic money represents a monetary value that is stored electronically, including magnetically, is issued upon receipt of funds so that a payment transaction can be conducted, and that is accepted by a natural or legal entity other than the electronic money provider.

Bank computers back up e-money systems with fiat money. E-payment systems are essentially electronic equivalents of cash.

Electronic Money Institutions (EMIs) are licensed to release electronic money. With this method, companies can top up their electronic wallets, purchase virtual currencies, and pay into forex accounts through quasi-cash operations.

Your business is also able to become an EMI institution with the license. An EMI institution is a company that issues digital currencies to individuals and corporations.

In the absence of an electronic money institution, it would be impossible to create virtual currency wallets, third-party payment services, and other resources that use virtual currency.

A PI (Payment Institution) cannot issue e-money. The ability to issue e-money is the primary difference between Electronic Money Institutions and Payment Institutions.

PIs and EMIs adopt different business models due to the contrasting legal treatment of payment accounts. As discussed in this article, several jurisdictions will be able to issue EMI licenses in 2023.

Since the Dutch licensing process is relatively short, it is relatively easy to obtain an EMI license. In cases where it is possible to complete a license within 6 months, the Dutch regulator, Nederlandsche Bank (DNB), issues licenses within a realistic timeframe of 9 months, while most European regulators require 12 to 15 months.

This expedited process allows companies to take advantage of emerging opportunities faster, as well as get a quicker route to market entry.

Availability of local presence requirements for international teams in the Netherlands is flexible. Many other regulatory agencies require a significant local presence, but Dutch regulators do not.

A single application only requires two local directors, so the majority of the team can be from another European country. Fintech firms can leverage the diverse talent pools in the Netherlands as a result of a favorable regulatory environment.

In the Netherlands, most authorizing documents may be submitted in English, which is one benefit of obtaining an EMI license there. English documentation is accepted in the Netherlands instead of local language documentation, thus reducing translation costs and burdens. International applicants can appeal more efficiently due to this flexibility.

  1. The issuance and provision of electronic money
  2. Allow payment methods other than credit cards to be accepted and manage them
  3. A payment account. Account cards can be used to purchase goods and services, place and withdraw cash, and deposit and withdraw cash from such accounts. It is also possible to transfer funds and to set up direct debits.
  4. Merchandise offered by merchants. A license issued by a payment institution is required to provide merchant services. Merchants can use credit cards to pay the company as a master merchant.
  5. Funds transfer. In addition to providing payment services, a payment institution can also provide money remittance or transfer services. Providers of payment services can use this service to make cross-border payments internationally.
  6. Initiating payments through services. By removing Visa and Mastercard networks from the payment process, an initiator can initiate payments directly from a user's bank account with the user's consent. Paying directly from the user's bank account to a merchant retailer's bank account is possible for payment service providers who hold a payment institution license.
  7. User account information. In accordance with the user's consent, this permission permits payment service providers to view consolidated account information in one location.

There are significant differences between PIs and EMIs and bank accounts, regardless of what some customers may think.

Examining the institution that offers these accounts will allow us to assess account functionality.

In comparison with EMI accounts, PI accounts are limited because they cannot hold money for their users.

  • As soon as PI funds are entered into an account, they are likely to be spent, transferred, or withdrawn relatively quickly.
  • E-wallets can be opened and money can be withdrawn and bills paid online with the EMI license, unlike the EMI license, which does not allow for e-wallets.

Because of these differences in functionality, capital requirements also differ significantly between institutions.

Legal entities must be created in the Netherlands before payment services activities can be conducted.

It is required that the applicant meet a minimum fund demand. There is a minimum authorization requirement of €350,000 in the Netherlands for an EMI permit.

A good fit and proper fit is determined by evaluating the key employees of the applicant company. Qualifications, experience, and integrity are essential for these individuals to fulfill their roles effectively.

A marketing strategy and risk management plan must also be included in applicants' business plans. The proposed commerce model must demonstrate its viability and sustainability as part of the commerce plan.

As a Dutch EMI/EMI authorized provider of electronic money services, you can provide your services without obtaining additional licensing in all member countries of the European Economic Area.

Austria, Belgium, Bulgaria, Croatia, Cyprus (Republic of), the Czech Republic, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden are members of the European Economic Area.

  1. Company information
  2. Plan of operations
  3. An analysis of the business plan and the financial forecast
  4. Provide a brief description of your business structure
  5. The original investment document
  6. A description of how client funds are safeguarded
  7. Mechanisms for ensuring compliance and governance
  8. Follow the security incident procedure when handling complaints and security incidents
  9. The process for filing, monitoring, tracking, and restricting sensitive payment data
  10. Measures to ensure business continuity and recovery
  11. Monitoring transactions, fraud, and performance by collecting statistical data
  12. Policy for protecting information
  13. Assessment and mitigation of risk to manage your AML/CTF requirements
  14. The shareholders' information
  15. Extensive outsourcing arrangements

The Dutch regulator must decide on a complete application within three months of receiving it. Five to six months are usually required for the license to be obtained.

AML procedures are highly emphasized by Dutch regulators, who expect that all AML-specific requirements are met.This is not a unique quality of Dutch standards, but it is a well-known characteristic of DNB standards.

AML rules and procedures should be thoroughly understood and implemented by fintech companies before they can qualify for an EMI grant.

As a result of the DNB's strict anti-money laundering measures, the integrity and respectability of the Dutch financial system is enhanced.

Additional services for Netherlands

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