Fintech & digital payments rules in Netherlands (2026)

The European Parliament and Council of the EU struck a provisional deal on PSD3 and the directly-applicable Payment Services Regulation (PSR), which will replace PSD2. Once formally adopted and published (expected 2026), an 18-month transposition window follows, putting Dutch PSPs on a compliance deadline of approximately late 2027–mid 2028.

From 9 October 2025, payment service providers in the Netherlands must be able to send instant euro credit transfers and offer a Verification of Payee service confirming that a payee's name matches the provided IBAN, per EU Regulation 2024/886. Non-bank PSPs (payment institutions, e-money institutions) have until 9 April 2027.

The Netherlands chose to cut the EU-default 18-month MiCA transitional window to only six months, ending the grandfathering of DNB-registered VASPs on 30 June 2025. From that date, all crypto-asset service providers must hold a MiCA CASP authorisation from AFM (conduct supervision) or comply with DNB's prudential rules for ART/EMT issuers.

Title V of Regulation (EU) 2023/1114 (MiCA) became applicable on 30 December 2024, making CASP authorisation mandatory across the EU. In the Netherlands, the AFM issues CASP licences while DNB supervises issuers of asset-referenced tokens and e-money tokens; capital requirements range from €50,000 to €150,000 depending on services offered.

DNB imposed a €2,850,000 administrative fine on Foris DAX Europe B.V. (Crypto.com) for providing crypto exchange and wallet services in the Netherlands from May 2020 to November 2022 without the Wwft registration required since AMLD5 implementation, despite repeated prior warnings from DNB.

Regulation (EU) 2023/1114 entered into force on 29 June 2023, creating the first comprehensive EU-wide licensing and disclosure framework for crypto-asset issuers and service providers. The Netherlands designated AFM as competent authority for most CASP licensing and DNB for prudential oversight of ART/EMT issuers, replacing the Wwft registration regime.

DNB imposed a €3,325,000 administrative fine on Coinbase Europe Limited for operating crypto exchange and custody services in the Netherlands from 15 November 2020 to at least 24 August 2022 without DNB registration under the Wwft. The case was the second in a series of high-profile enforcement actions under the 2020 crypto-registration regime.

DNB publicly announced a €3,325,000 category-3 administrative fine on Binance for offering crypto exchange and wallet services in the Netherlands from May 2020 to at least December 2021 without Wwft registration. Binance subsequently withdrew from the Dutch market, establishing the enforcement template applied to Coinbase and Crypto.com.

The Netherlands implemented the Fifth Anti-Money Laundering Directive (AMLD5) via an amendment to the Wwft, making virtual-currency exchange providers and custodian wallet providers subject to mandatory AML registration with DNB. Firms already active were given a six-month transitional window to apply; all non-registered entities had to cease Dutch operations thereafter.

Following Dutch Senate approval on 4 December 2018, PSD2 was transposed into the Wft and Civil Code, adding Payment Initiation Services (PIS) and Account Information Services (AIS) as regulated activities requiring DNB authorisation or registration. Banks were mandated to open APIs to third-party providers; implementation was delayed by conflicts between PSD2 and GDPR data-sharing rules.

The Netherlands transposed EU Directive 2007/64/EC (PSD1) into the Wft by 1 November 2009, introducing the 'payment institution' as a new DNB-licensed category distinct from banks, enabling non-bank firms to provide payment services across the EU. A transitional regime allowed entities already active before December 2009 to continue operating until 30 April 2011.

The Wet op het financieel toezicht (Wft) consolidated Dutch financial sector supervision under a single statute, establishing DNB as prudential supervisor and AFM as conduct supervisor in a 'twin-peak' model. The Wft has served as the primary legal basis for all payment institution, electronic money institution, and fintech licensing in the Netherlands ever since.