Digital Payments & Fintech - Netherlands

Payment institutions and electronic money institutions require a DNB licence under PSD2 as implemented in the Wft; DNB supervises financial position, operational/security risk, strong customer authentication and secure communication, and maintains a public register of authorised firms.

PSD2 (in the Wft) establishes licensed access to payment accounts: payment initiation services (PIS) and account information services (AIS) require DNB authorisation/registration and must meet access-to-account, strong customer authentication and secure communication rules.

Under the EU Instant Payments Regulation, Dutch PSPs have been able to receive instant euro credit transfers since 9 January 2025 and must be able to send them and offer Verification of Payee from 9 October 2025; DNB is the competent authority overseeing compliance.

Under MiCA, crypto-asset service providers must hold a licence; the AFM is the primary supervisor for CASPs (DNB for asset-referenced and e-money tokens). The Dutch transitional period ended 30 June 2025, so a MiCA licence is required to operate from 1 July 2025; the AFM publishes a register of authorised CASPs.

Buy-now-pay-later is currently largely unregulated, but the revised Consumer Credit Directive (Directive (EU) 2023/2225) is being transposed into the Wft; from 20 November 2026 most BNPL providers will need an AFM licence and must perform creditworthiness checks and bar credit to minors. The AFM has publicly called for stronger consumer protection in the interim.

Supervision follows the Dutch twin-peaks model: DNB handles prudential authorisation/supervision of payment and e-money institutions, while the AFM oversees conduct, consumer credit (incl. BNPL) and most crypto-asset service providers.