Twin supervisors
DNB focuses on prudential soundness and specified market-access files; the AFM focuses on conduct, markets and its allocated licensing routes.
Jurisdiction dossier
Netherlands financial permissions and regulator dossier
Dutch market access is organised through the Financial Supervision Act and sector statutes, not a single licence. De Nederlandsche Bank (DNB) leads prudential market access for banks, payment and e-money institutions, insurers, pension institutions and trust offices. The Netherlands Authority for the Financial Markets (AFM) licenses investment firms, fund managers, financial service providers, crowdfunding providers and MiCA CASPs, with DNB involved in prudential and qualifying-holding issues where the law allocates them. The ECB decides euro-area bank authorisations. This is the map as of July 2026.
Route facts
Netherlands regulatory map
Banking decision
The ECB grants and withdraws Dutch credit-institution authorisations within the SSM, working with DNB.
Restricted routes
Exempt PI and EMI statuses and activity exclusions are narrower than full authorisation and do not support the same EEA reach.
Trust-office licence
Dutch trust services require a DNB licence or valid exemption under the Act on the Supervision of Trust Offices.
Crypto split
AFM handles MiCA CASP applications and notifications; DNB addresses prudential safeguards and qualifying holdings in the coordinated review.
Review date
Last reviewed against official DNB, AFM and ECB material on 11 July 2026.
Start with the activity
Licence, exemption and registration have different effects
Dutch law deliberately distinguishes full authorisation from an exemption or register entry. A DNB-authorised payment institution may provide only its approved payment services. An exempt payment institution remains within the conditions and scale limits of the exemption and cannot use the European passport. The same distinction applies to authorised and exempt electronic money institutions. Account-information providers, agents and distributors have their own status, which does not turn them into the principal licensed institution.
MiCA is now the operating crypto perimeter. The former DNB AML registration for fiat- crypto exchange and custody providers ceased to be an operating alternative when the Dutch transition ended on 30 June 2025. AFM authorisation under Article 63, or an Article 60 notification available to specified existing financial entities, controls current CASP status. A previous AML register entry, Chamber of Commerce registration, sandbox discussion or pending application is not permission. Verify every firm in the DNB or AFM public register and read the service scope rather than the trading name.
Permission matrix
Netherlands licence, authorisation and exemption families
| Permission family | Regulator and instrument | Activities and exclusions | Entry and capital basis |
|---|---|---|---|
| Permission family Banks and credit institutions | Regulator and instrument ECB authorisation with DNB assessment under the SSM and Dutch Financial Supervision Act | Activities and exclusions Deposit taking and lending plus the banking and investment activities available under law and the grant; payment or credit-company status alone never permits public deposits | Entry and capital basis Dutch establishment, qualifying holders, fit-and-proper management, programme, governance, recovery planning and CRR capital, liquidity and risk evidence |
| Permission family Authorised payment institution | Regulator and instrument DNB authorisation under the Financial Supervision Act and PSD2 implementation | Activities and exclusions Approved account, execution, card, acquiring, money-remittance, payment-initiation or account-information services; PI status does not permit e-money issuance or deposit taking | Entry and capital basis Initial and ongoing own funds depend on services and volume; safeguarding, governance, integrity, security, AML/CFT, agent and outsourcing arrangements are assessed |
| Permission family Exempt payment institution and registered AISP | Regulator and instrument DNB exemption or registration under the Dutch payments framework | Activities and exclusions Limited Dutch payment activity or account-information-only service within the statutory conditions; no unrestricted EEA passport follows from exempt status | Entry and capital basis Volume, customer and territorial limits, professional cover where applicable, management integrity and reporting replace parts of the full PI prudential route |
| Permission family Authorised electronic money institution | Regulator and instrument DNB authorisation under the Financial Supervision Act and e-money rules | Activities and exclusions Issue and redeem e-money and provide approved payment services; funds received are safeguarded and do not become bank deposits | Entry and capital basis Legal person, Dutch head office, EMD initial capital, ongoing own funds, safeguarding, redemption, governance, distributor and agent oversight |
| Permission family Exempt electronic money institution | Regulator and instrument DNB exemption and public-register entry under the Dutch e-money framework | Activities and exclusions Limited e-money issuance within the exemption conditions; the provider may not start before register entry and may not use the European passport | Entry and capital basis Eligibility, scale and territorial conditions, sound management, safeguarding and continuing reporting must remain satisfied throughout the exemption |
| Permission family Exchange institution | Regulator and instrument DNB authorisation or exemption under the Financial Supervision Act for exchange transactions | Activities and exclusions Exchange cash currency or make specified cash disbursements against cards or paper instruments within the grant; exchange status does not permit remittance, payment accounts, e-money, investment services or deposits | Entry and capital basis Dutch market access, trustworthy policymakers, ethical and controlled operations, integrity-risk and AML/CFT controls, cash procedures and public-register entry before activity |
| Permission family Investment firm and trading venue | Regulator and instrument AFM licence under the Financial Supervision Act and MiFID II, with DNB prudential involvement where allocated | Activities and exclusions Reception and transmission, execution, dealing, portfolio management, advice, underwriting, placement, custody and MTF or OTF operation only where granted | Entry and capital basis Dutch registered office and actual head office, qualifying holders, suitable policymakers, prudential class, client-asset controls and conduct systems |
| Permission family UCITS manager and AIFM | Regulator and instrument AFM authorisation or registration under Dutch UCITS and AIFMD implementation | Activities and exclusions Manage collective portfolios and perform permitted ancillary services; an exempt or registered manager is not a fully authorised AIFM and has narrower marketing options | Entry and capital basis Full or sub-threshold status sets own funds, substance, risk, valuation, depositary, delegation, leverage, reporting and investor-disclosure requirements |
| Permission family Insurance and reinsurance | Regulator and instrument DNB prudential authorisation and AFM conduct supervision under the Financial Supervision Act and Solvency II | Activities and exclusions Underwrite approved life, non-life or reinsurance classes; insurance distribution and underwriting are separate functions | Entry and capital basis Dutch head office, qualifying holders, fit-and-proper board and key functions, governance, technical provisions, minimum and solvency capital |
| Permission family Pension fund and premium pension institution | Regulator and instrument DNB prudential supervision and AFM conduct supervision under Dutch pension and financial-supervision law | Activities and exclusions Operate the pension arrangement or defined premium-pension function within its statutory scope; neither status is a general insurer, bank or investment firm | Entry and capital basis Governance, key functions, funding or capital, investment policy, outsourcing, member communication and supervisory reporting follow the exact institution type |
| Permission family Trust office | Regulator and instrument DNB licence or exemption under the Act on the Supervision of Trust Offices 2018 | Activities and exclusions Provide reserved trust services such as company-domicile combinations, sale or intermediation of legal entities, trustee or director services within the licensed scope | Entry and capital basis Dutch substance, ownership transparency, suitable management, integrity, client acceptance, independent compliance and audit, professional operations and AML controls |
| Permission family Consumer-credit and financial service provider | Regulator and instrument AFM licence under the Financial Supervision Act for the applicable offering, advice, intermediation or credit activity | Activities and exclusions Offer credit or advise and intermediate in credit, insurance or other designated retail financial products; the service-provider licence is not deposit taking or investment dealing | Entry and capital basis Professional competence, reliability, operational integrity, consumer treatment, disclosure and professional cover or financial-resource rules depend on the activity |
| Permission family Crowdfunding service provider | Regulator and instrument AFM authorisation under Regulation (EU) 2020/1503 | Activities and exclusions Operate an ECSPR investment- or lending-based platform; the permission does not itself authorise deposit taking, balance-sheet lending or a regulated market | Entry and capital basis Prudential safeguards, governance, conflicts, investor protection, credit assessment where used, complaints, default handling and business continuity |
| Permission family Crypto-asset service provider | Regulator and instrument AFM Article 63 MiCA authorisation or Article 60 notification, with DNB prudential and qualifying-holding assessment | Activities and exclusions Approved custody, platform, exchange, execution, placing, order, advice, portfolio-management or transfer services; no automatic fiat-payment or banking scope | Entry and capital basis EU registered office and effective management, suitable owners and managers, MiCA safeguards, custody, complaints, conduct, ICT, conflicts and AML/CFT evidence |
| Permission family Market infrastructure and clearing | Regulator and instrument AFM and DNB authorisation or recognition under Dutch and EU market-infrastructure legislation | Activities and exclusions Operate a regulated market, clearing or settlement function only under its specific market-infrastructure status; an investment-firm licence alone is insufficient | Entry and capital basis Ownership, governance, financial resources, default management, settlement, resilience, access, surveillance and recovery requirements follow the infrastructure type |
| Permission family Gambling, betting, lotteries and gaming machines | Regulator and instrument Kansspelautoriteit licence under the Betting and Gaming Act, including the remote-gambling route or the applicable land-based, lottery or machine category | Activities and exclusions Offer only the online or offline games and categories stated in the Ksa licence; a lottery, machine or model approval is not a remote-gambling licence and no DNB or AFM financial authority follows | Entry and capital basis Integrity, continuity, responsible-gambling duty of care, addiction prevention, Cruks where applicable, game-system control, AML/CFT, advertising, player funds, reporting and exit arrangements depend on category |
Entry test
Dutch substance, suitability and financial resources
The applicant must use an eligible legal form and locate its registered office and actual head office or effective management in the Netherlands where the instrument requires it. DNB and the AFM assess direct and indirect qualifying holders, source of funds, policymakers, supervisory directors and key officers for suitability and integrity. The operating plan must identify compliance, risk, MLRO, finance, audit, information security and responsibility for outsourced functions. A letterbox model fails the substance analysis even where vendors are used for technology or administration.
Capital follows the permission: CRR for banks, payment and e-money calculations for PI and EMI, the investment-firm prudential class, Solvency II for insurers, pension-specific funding, MiCA safeguards for CASPs and prudential safeguards for crowdfunding. Client money, e-money float, financial instruments and crypto-assets each have their own safeguarding or custody treatment. Current DNB and AFM fee regulations govern charges. Figures and statutory clocks should be taken from the precise application page at filing, not generalised across routes.
Application path
A Dutch authorisation, stage by stage
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Fix the legal perimeter and regulator split
Map every service, asset flow, client type, custody point, exchange, gambling and group function to DNB, AFM, ECB or the Ksa and record whether it needs authorisation, exemption, registration, notification or product approval.
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Use pre-application guidance
DNB's market-access pages and AFM sector portals publish route-specific forms and guidance. Confirm legal form, substance, proposed policymakers, prudential method and filing channel.
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Build an evidence-led operating file
Prepare programme, forecasts, ownership, suitability files, governance, AML/CFT, safeguarding or client assets, outsourcing, DORA and ICT, complaints, continuity and wind-down evidence.
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Complete coordinated review
Answer completeness and substantive questions and any DNB or AFM cross-referral. Interviews, suitability assessments and amendments may be required; a pending file grants no operating status.
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Satisfy conditions and register the scope
Complete capital, appointments, systems, reporting and any conditions before starting. Cross-border services begin only after the applicable notification has taken effect.
After authorisation
Ongoing supervision and change in control
Dutch firms maintain capital or solvency, governance, AML/CFT, audit, regulatory returns, safeguarding or client-asset controls, complaints, conduct, product governance, outsourcing, incident reporting and DORA resilience required by their route. An exemption continues only while every condition remains met. New services, customer classes, branches, agents, delegates, critical outsourcing or token functions may require prior approval, a variation or notification.
A transaction transfers shares in the supervised company, not the licence itself. Proposed qualifying holdings and control changes are assessed under the DNB, AFM or ECB procedure allocated to the institution. Diligence should reconcile the public register and decision, capital headroom, safeguards, client assets, complaints, inspections, enforcement, outsourcing and remediation. Previous DNB crypto registration has no continuing value as a MiCA permission. The competent authority decides on the incoming holder; no adviser can guarantee approval.
Territorial reach
A Dutch authorisation is not an all-services passport
A fully authorised Dutch PI, EMI, investment firm, manager, insurer or CASP can use the EU or EEA cross-border mechanism available under its governing legislation after the required notifications. Only services on the home-state grant travel through that mechanism. Exempt PI and EMI status, exchange or trust-office licensing, a national consumer-credit licence, Ksa gambling permission and statutory exclusions do not acquire EEA reach merely because the company is Dutch. Host-state conduct, consumer and general-good rules remain relevant, and third-country activity needs a separate target-market review.
Verify it yourself
Primary Netherlands sources
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DNB Open Book on Supervision
dnb.nl publishes market-access and ongoing-supervision pages for banks, PI and EMI, insurers, pensions, trust offices and the relevant exemptions.
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DNB and AFM public registers
The official registers show the institution type, authorisation or exemption and service scope. A Chamber of Commerce entry does not replace them.
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AFM investment and fund-manager portals
afm.nl publishes licensing, variation, exemption and register material for investment firms, AIFMs, UCITS managers, financial service providers and crowdfunding.
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AFM MiCA portal
The CASP pages identify AFM as first contact, DNB's prudential and qualifying-holding role, Article 60 and 63 procedures, forms and the ended Dutch legacy transition.
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ECB Banking Supervision
The ECB licensing and qualifying-holding guides govern Dutch bank authorisations within the SSM in cooperation with DNB.
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DNB exchange and Ksa gambling registers
DNB publishes the exchange-institution licence or exemption route and register; kansspelautoriteit.nl publishes remote, land-based, lottery and gaming-machine permission routes and the Kansspelwijzer licensee register.
01 Can an exempt Dutch EMI operate across the EEA?
No. DNB states that an exempt EMI cannot use the European passport or expand its exempt activity outside the Netherlands. A full EMI authorisation and the relevant notification are required for harmonised cross-border activity.
02 Is the old DNB crypto registration still enough?
No. The Dutch transition ended on 30 June 2025. Current CASP activity requires MiCA authorisation or an eligible Article 60 notification from the AFM or another EU authority, with the permitted services shown in the current register.
03 Who licenses a Dutch CASP?
The AFM handles Article 63 applications and Article 60 notifications and is the first contact. DNB is involved in prudential safeguards and qualifying-holding matters under the Dutch allocation of MiCA responsibilities.
04 Does a trust-office licence permit investment management?
No. It covers reserved trust services within the Wtt scope. Investment advice, portfolio management, custody, payments or deposit taking must be tested under their own Financial Supervision Act permissions.
05 Can an authorised Dutch company be acquired?
Shares may be acquired subject to the applicable qualifying-holding process. The licence stays with the company, incoming controllers and funding are assessed, and the permission scope and supervisory history require full diligence.
Reviewed by the SKY7 advisory team. Last reviewed: 11 July 2026. This dossier is general information, not legal, regulatory, tax, investment or financial advice. It describes the Dutch framework as of July 2026. Verify the current DNB and AFM rules, public registers, licence or exemption conditions, Ksa rules and register, fee regulations and ECB procedures before relying on a route. No regulator outcome is promised.
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Build the Dutch permission map first
Send the services, customers, flow of funds, custody model, target markets and ownership chain. SKY7 will identify the DNB, AFM, ECB and Ksa permissions, exemption limits and evidence gaps before a filing or acquisition decision. Fees are on request.