Getting a payment, e-money or crypto licence in the Netherlands as a founder from outside the EU
You run a fintech or crypto business from outside the EU and want a licence that covers Dutch and European clients. In the Netherlands, DNB licenses payment and e-money institutions for an application fee of EUR 10,400, and the AFM licenses crypto-asset service providers at EUR 200 per hour of work, capped at EUR 100,000. Either licence goes to a company established in the EU and managed there, so the Dutch entity and the people who run it come before the file.
What a non-EU founder faces in the Netherlands
Six points, who they apply to and how long they take.
| Obligation | Rule | Who | When or how long | Official source |
|---|---|---|---|---|
| Payment institution (PI) licence | Licence from DNB, application fee EUR 10,400 | A company with its head office and part of its payment business in the Netherlands | 3 months from a complete file; DNB says it often takes longer | DNB, fee regulation |
| E-money institution (EMI) licence | Licence from DNB, application fee EUR 10,400, initial capital of at least EUR 350,000 | The company that will issue e-money | No decision period in the sources we read | Fee regulation, EMD2 art. 4 |
| Crypto-asset service provider (CASP) licence | Authorisation from the AFM, EUR 200 per hour of work, capped at EUR 100,000 | A company with a Dutch registered office, effective management in the EU and an EU-resident director | 40 working days from a complete file | Fee regulation, MiCA art. 59 and 63 |
| Token filings | EUR 4,800 for an EMT notification, EUR 15,000 for an ART authorisation | Token issuers | One-off charge | Fee regulation |
| Crypto transitional period | 6 months in the Netherlands, ended at the end of June 2025 | Crypto firms that relied on the transition | Over: a MiCA licence is needed now | ESMA list |
| Passporting | DNB or the AFM forwards your notification to each host country | A licensed Dutch PI or CASP | PI: 1 month, then 1 month. CASP: 10 working days, start by the 15th calendar day | PSD2 art. 28, MiCA art. 65 |
The sections below take each line in turn. Fees are those of the Dutch fee regulation in the version in force since 22 September 2026.
DNB for payments, the AFM for crypto
A flat fee at DNB, an hourly fee with a ceiling at the AFM.
De Nederlandsche Bank (DNB) licenses payment institutions and electronic money institutions under articles 2:3a and 2:10a of the Financial Supervision Act (Wft). The Dutch Authority for the Financial Markets (AFM) licenses crypto-asset service providers under MiCA (MiCA art. 62). A project that combines payments and crypto deals with both, each with its own file and fee. The fees come from the regulation on charges for one-off supervisory acts (Regeling bekostiging financieel toezicht eenmalige handelingen), in the version in force since 22 September 2026 (wetten.overheid.nl).
EUR 10,400 for a PI or an EMI
Item Wft.D1.01 of the fee regulation sets EUR 10,400 for a payment service provider, and item Wft.D1.05 sets the same amount for an electronic money institution.
EUR 200 per hour, up to EUR 100,000
For a CASP authorisation, item EU.A1.08 charges EUR 200 for each hour of AFM work on the file, with a ceiling of EUR 100,000. At that rate, the ceiling corresponds to 500 hours of work.
Token issuers pay separate charges under the same regulation: EUR 4,800 for an e-money token (EMT) notification (item EU.D1.03) and EUR 15,000 for an asset-referenced token (ART) authorisation (item EU.D1.02) (fee regulation).
How long DNB and the AFM take
The legal periods run from a complete file, not from the first submission.
3 months for a payment institution
DNB must decide within 3 months of receiving the application, or of receiving all the information if the file was incomplete (PSD2 art. 12). DNB's own page on the duration of an application, dated March 2022, warns that it often takes longer in practice (DNB). The legal period has not changed since.
40 working days for a CASP
Under MiCA, the AFM acknowledges receipt within 5 working days and checks within 25 working days whether the file is complete. It decides within 40 working days of a complete file and informs you of the decision within 5 working days (MiCA art. 63).
The sources we read give no decision period for an e-money institution, and no official figures on the time DNB or the AFM actually took in 2025 or 2026.
What a non-EU founder has to place in the EU
Your company abroad cannot hold the licence. The applicant needs its own seat, management and capital.
Payment licences at DNB
PSD2 reserves the licence to a legal person established in a member state, with its head office in the same state as its registered office and at least part of its payment business there (PSD2 art. 11(1) and 11(3)). For DNB, that means a Dutch company with its head office in the Netherlands.
Crypto licences at the AFM
MiCA asks for a registered office in a member state where the firm provides part of its services, effective management in the EU and at least one director resident in the EU (MiCA art. 59(2)). An AFM applicant therefore needs a Dutch registered office and part of its business in the Netherlands.
A team based entirely outside the EU does not qualify
If every founder and director lives outside the EU, a CASP file fails the MiCA test of an EU-resident director and effective management in the EU. Decide who will run the Dutch company, and from where, before you draft the business plan.
Initial capital
PSD2 sets the initial capital of a payment institution by service: EUR 20,000 for money remittance only (point 6 of Annex I), EUR 50,000 for payment initiation (point 7) and EUR 125,000 for the services in points 1 to 5 (PSD2 art. 7). An e-money institution needs at least EUR 350,000, and under method D its own funds must reach at least 2% of its average outstanding e-money (EMD2 art. 4 and 5(3)). A CASP needs EUR 50,000, EUR 125,000 or EUR 150,000 depending on its class (MiCA art. 67 and Annex IV).
No transition left for crypto firms
The Dutch grace period lasted 6 months, against 12 to 18 months in Germany, Ireland or France.
Ended at the end of June 2025
MiCA let member states run a transitional period for crypto firms until 1 July 2026 at the latest, and shorten it. The Netherlands chose 6 months, which ended at the end of June 2025. Since 1 July 2026, no transitional period runs anywhere in the EU (ESMA list, MiCA art. 143(3)).
A narrow exemption
A non-EU firm without a MiCA licence may serve an EU client only when the client takes the exclusive initiative. Any solicitation in the EU, by any means and including through a related entity, removes the exemption, whatever the contract says. It does not allow you to offer the client new products (MiCA art. 61).
In practice, marketing crypto services to Dutch users from outside the EU requires a MiCA licence, either from the AFM or from another member state and passported into the Netherlands.
Using a Dutch licence in other EU countries
The notification goes through DNB or the AFM, with fixed periods.
1 month, then 1 month
DNB sends your notification to the host country within 1 month of receiving the complete file. The host authority then has 1 month to assess it (PSD2 art. 28(2)).
10 working days, start by day 15
The AFM forwards the information to the host countries within 10 working days. You may start there at the latest on the 15th calendar day after your notification (MiCA art. 65).
The capital levels, establishment tests and passport periods come from PSD2, EMD2 and MiCA and are the same in every member state. PSD3 and the Payment Services Regulation reached a provisional agreement on 27 November 2025, but as of 25 October 2026 they had no plenary vote and no publication in the Official Journal, so PSD2 and EMD2 still apply (European Parliament). Our country-by-country comparison of fintech licences sets the Dutch authorities and fees against the rest of Europe.
From business model to Dutch licence
In the order a newcomer meets them. Only the legal periods are shown.
Match your business to a licence
A PI or EMI licence from DNB for payments or e-money, a CASP licence from the AFM for crypto-asset services.
Set up the Dutch company, its management and its capital
Head office in the Netherlands for a PI. For a CASP, a Dutch registered office, effective management in the EU and an EU-resident director.
Submit the file to DNB or the AFM
EUR 10,400 at DNB for a PI or EMI; EUR 200 per hour, up to EUR 100,000, at the AFM for a CASP.
Acknowledgment and completeness check
The AFM confirms receipt, then whether the file is complete. At DNB, the 3 months run from the date it has all the information.
Decision
DNB warns that a PI decision often takes longer. The AFM informs you of its decision within 5 working days.
Passport notifications
PI: 1 month for DNB, then 1 month for the host authority. CASP: 10 working days for the AFM, start by the 15th calendar day.
What the official sources do not settle
The official sources we read leave several points open: the time DNB and the AFM actually take in 2025 and 2026, the decision period and passport steps for an e-money institution, whether the Netherlands offers the lighter, non-passportable regimes PSD2 and EMD2 allow for small firms, whether the AFM asks more of directors than EU residence, the language of the file, the penalties for unlicensed activity, and whether a crypto firm that transfers or holds e-money tokens also needs a payment licence. Confirm each with DNB, the AFM or a licensed adviser in the Netherlands before you plan around it.
What Balt Partners coordinates
One contact in Riga for the planning around your Dutch licence.
Licence and authority map
Which licence your model needs, which Dutch authority receives the file, the fee and the legal periods, in one calendar with the passport steps.
Dutch filing by a licensed adviser
For the DNB or AFM application, we bring in a licensed adviser in the Netherlands, who handles the filing and the exchanges with the authority.
Management and substance checklist
Where the head office sits, who runs the company and which director is resident in the EU: the points to settle before the file goes in.
A Latvian SIA for the wider group
If your group also needs an EU company outside the licensed entity, we form a Latvian SIA with its bank account and accounting set-up. It is a separate company and does not hold a Dutch licence.
Still choosing the country? Start from our guide to fintech licences in Europe, and see EU company formation for non-residents for the company side.
Questions from non-EU founders about Dutch licences
Not in its own name. PSD2 reserves the licence to a legal person established in an EU member state, with its head office in the state of its registered office and part of its payment business there. For DNB, that means a Dutch company with its head office in the Netherlands.
EUR 10,400 for either licence, under the Dutch fee regulation in force since 22 September 2026. Initial capital comes on top: EUR 20,000 to EUR 125,000 for a payment institution, depending on its services, and at least EUR 350,000 for an e-money institution.
The legal period is 3 months from a complete file. DNB itself warns that it often takes longer in practice, and we found no official figures on actual processing times in 2025 or 2026.
The AFM authorises crypto-asset service providers. It charges EUR 200 per hour of work on the application, capped at EUR 100,000. Under MiCA it must decide within 40 working days of a complete file.
Only on reverse solicitation, when the client takes the exclusive initiative. Any solicitation in the EU, by any means and including through a related entity, removes that exemption. The Dutch transitional period ended at the end of June 2025.
MiCA requires at least one director resident in the EU, not specifically in the Netherlands, and effective management in the EU. Confirm with the AFM whether it expects more for your file.
Yes, through passporting. DNB forwards a payment institution's notification within 1 month of a complete file, and the host authority has 1 month to assess it. The AFM forwards a CASP's notification within 10 working days, and the CASP may start at the latest on the 15th calendar day after notifying.