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PSD3 in the Netherlands: what DNB licensed EMIs and payment institutions must do

By Harry Khan, Founder · Published 8 November 2026 · Last reviewed 8 November 2026

Summary
  • Dutch payment and e-money institutions must show De Nederlandsche Bank that they meet PSD3 within 27 months of entry into force to keep their services.
  • The Netherlands has 65 authorised payment institutions and 28 EMIs, plus 61 firms under national waivers or exemptions, on the EBA register at 30 October 2026.
  • DNB's March 2026 review found exit plans too optimistic, too narrow and short on dependencies. PSD3's winding-up plan asks for the same things DNB found missing.
  • DNB already recognises three safeguarding methods: a client funds foundation, a separate asset account and an insurance policy or guarantee.
  • Firms under the Dutch exemption regime and waived EMIs have their own transitional position and should confirm their route with DNB early.

The short answer

PSD3 replaces PSD2 and the Second E-Money Directive with a single framework for payment institutions, and e-money issuance becomes one of the payment services they can be authorised for. Every payment institution and electronic money institution (EMI) licensed by De Nederlandsche Bank (DNB) under the Financial Supervision Act (Wft) will need to show that it meets PSD3 within 27 months of entry into force. Institutions that do are treated as authorised under PSD3. Those that do not must stop the services concerned.

Dutch commentators have stressed that existing institutions do not go through a full new application, but they must provide the information PSD3 lists and DNB will test it against the full set of authorisation conditions. DNB's own work in 2026 on exit plans and on its application process shows where it will look. Our PSD3 re-authorisation guide explains the EU-wide process.

The Dutch sector in numbers

The Netherlands has one of the most varied payments sectors in the EU, with a high number of payment institutions and an unusually large group of firms under national waivers and exemptions. The table counts firms with a current Dutch home licence or registration on the EBA Central Register at 30 October 2026, from the Buckingham register of licensed EU payment and e-money firms.

Firms with a home licence in the NetherlandsNumber
E-money institutions28
Payment institutions65
E-money institutions under a national waiver25
Payment institutions under the national exemption36
Firms passporting into at least one other country71

Payment acquirers, payment service providers for e-commerce and merchant platforms make up a large part of the authorised group. The 61 waived and exempt firms are a particular feature of the Dutch market and have their own position under PSD3, covered below.

The timeline

StepTiming
Council adopts its first reading position on PSD3 and the PSR29 October 2026
European Parliament approves the texts in plenaryExpected around the end of 2026
Entry into force20 days after publication in the Official Journal
PSD3 applies through national law; the PSR applies directly21 months after entry into force
Transition for existing institutions ends27 months after entry into force, extendable by up to 3 months in exceptional cases

The Netherlands will transpose PSD3 by amending the Wft and its secondary regulations. Until those amendments are published, the exact Dutch procedure is not known. Dutch commentators expect DNB to rely on the information categories set out in PSD3 and to test compliance with Title II as a whole, which is why preparation should cover the full file rather than a short form.

What DNB found in exit plans

In March 2026 DNB published the results of a review of exit plans at a selection of payment and e-money institutions. It reminded the sector that every payment institution must have an exit plan, and it listed five findings.

DNB findingWhat PSD3's winding-up plan needs
Plans not kept up to date or uploaded to MijnDNBA current plan in the authorisation file, maintained as the business changes
Timelines for returning client funds too optimistic, especially with payment blocks or inactive customersA realistic, tested process for returning safeguarded funds in a disorderly wind-down
Dependencies on group entities and third parties missingCritical services mapped, with support agreed and documented in advance
Scenarios too narrow, mostly a sale or orderly wind-downSevere scenarios such as the sudden collapse of the parent, with liquidity to match
Costs underestimated; capital must be held until the licence is surrenderedCosted plan, funded from own resources, with minimum capital maintained throughout

DNB also noted that a licence can only be surrendered once all client balances have been paid out. That single point explains why the winding-up plan matters so much: the institution remains supervised, and must keep its capital, until the last customer is repaid. DNB updated its Open Book Supervision guidance to reflect the findings. Dutch institutions should treat that guidance as the starting point for the PSD3 plan. Our PSD3 winding-up plan guide covers the contents in more detail.

Safeguarding in the Netherlands

DNB's revised explanatory notes to its licence application form, published in March 2026, set out three safeguarding methods and the documents needed for each: a client funds foundation (stichting derdengelden), a separate asset account (rekening afgescheiden vermogen), or an insurance policy or guarantee. For the first two, applicants must show an opened account in the name of the foundation or separate asset account, or provide a signed commitment letter from the bank confirming that client acceptance is complete and the account is opened and blocked until the licence is granted.

PSD3 keeps the core methods but changes three things. EMIs must safeguard by the end of the business day after receipt rather than within five business days. Institutions must try to avoid holding all customer funds with one bank and manage concentration risk. And users must be told how their funds are protected and which insolvency law applies. Dutch institutions using a foundation should check that the foundation's account structure, governance and bank arrangements still fit, and those with a single bank should start opening a second account now, since bank onboarding is slow. A foundation structure also needs its board, statutes and bank mandates reviewed so that, in a wind-down, the foundation can pay customers directly without waiting for the institution's insolvency administrator. Our PSD3 safeguarding rules guide explains the PSD3 rule.

Exempt firms and waived EMIs

The Netherlands has 36 payment institutions under the national exemption and 25 EMIs under a national waiver on the EBA register. PSD3 keeps an exemption regime for smaller payment institutions subject to strict conditions on transaction value, and it gives e-money institutions that used the EMD2 waiver a longer transition period than authorised institutions. These firms should not assume they can simply carry on. Each should check whether it will qualify for the PSD3 exemption, whether its volumes are heading above the thresholds, and whether full authorisation is the better route for growth and for bank relationships.

Payment service providers, acquirers and platforms

Many Dutch payment institutions are acquirers or payment service providers for online merchants, often serving marketplaces and platforms. PSD3 and the PSR affect them in particular ways. Safeguarding applies where funds are still held at the end of the business day after receipt, and the recitals address acquiring through international card schemes, so acquirers should confirm how their settlement flows are treated. The commercial agent exclusion, which some marketplaces rely on to avoid licensing, keeps its place in the PSR but on tighter conditions, so platforms served by Dutch payment institutions may need to change their model or come under the institution's licence.

For the institution, the practical step is a review of each merchant segment: who holds the funds and for how long, whether the merchant or platform is itself licensed or exempt, and whether contracts and safeguarding arrangements reflect that. Where platforms change their model, the institution's own volumes and capital may change with them.

Questions for Dutch boards

A Dutch board preparing for PSD3 should be able to show DNB the following. A current exit plan, uploaded to MijnDNB, that addresses each of the five findings from the 2026 review. A safeguarding structure that will meet next business day timing and does not rely on a single bank. A PSD3 service list that matches the business, with passports aligned. A three-year capital projection under the PSD3 methods. And a named owner and timetable for the re-authorisation file. These points cover most of what the information required under PSD3 will ask for.

DNB is also likely to look at real presence. PSD3 requires the head office in the home member state and at least part of the payment business carried out there. Most Dutch institutions are clearly based in the Netherlands, but groups that use a Dutch licence mainly to serve customers elsewhere should check that management, control functions and some payment operations sit in the Netherlands.

Licence scope and the DNB application process

Under PSD3, an EMI authorised only to issue e-money will not automatically be able to provide related payment services such as acquiring or transfers; each service must be listed. Dutch institutions should map their activity to the PSD3 service list and confirm their passports match.

DNB's application process now has two phases: a completeness check, followed by the substantive assessment only once the file is complete. DNB generally asks once for missing documents and may declare an incomplete application inadmissible. Whatever process DNB adopts for existing institutions, the same discipline will help: a complete, indexed file with every document the notes list. Capital changes too, with e-money issuance carrying EUR 250,000 and core payment services EUR 150,000, added together. Our PSD3 capital requirements guide has the detail.

How Buckingham Capital Consulting helps

Buckingham Capital Consulting has advised payment and e-money firms since 2013 on licensing, compliance and banking, including Own Solutions' EMI licence from the Central Bank of Ireland and FCA authorisations for Nexpay, Orbital and Hryze. We prepare PSD3 gap analyses, exit and winding-up plans, safeguarding reviews and re-authorisation files for Dutch institutions, and help exempt firms decide between the PSD3 exemption and full authorisation. See our Netherlands EMI licence and Netherlands payment institution licence guides, or contact us to discuss your institution.

Questions

Do Dutch payment institutions need a new DNB licence under PSD3?

They must show DNB that they meet PSD3 within 27 months of entry into force. If they do, they are treated as authorised under PSD3 without a full new application.

What did DNB find in its 2026 exit plan review?

Plans were not always current, timelines for returning client funds were too optimistic, dependencies were missing, scenarios were too narrow and costs were underestimated.

Which safeguarding methods does DNB accept?

A client funds foundation, a separate asset account, or an insurance policy or guarantee, each with specific documents.

What happens to Dutch exempt payment institutions?

PSD3 keeps an exemption regime with conditions on transaction value. Each firm should check whether it qualifies or should seek full authorisation.

Do waived EMIs have longer to transition?

Yes. PSD3 gives e-money institutions that used the EMD2 waiver a longer transition period than authorised institutions.

Can a licence be handed back before customers are repaid?

No. DNB has said a licence can only be surrendered once all client balances have been paid out.

Sources

Get in touch: +44 7563 115980 (phone and WhatsApp) or [email protected].

This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.

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