Exempt electronic money institution registration (Vrijstelling elektronischgeldinstelling) (Netherlands)
The Exempt electronic money institution registration (Vrijstelling elektronischgeldinstelling) is issued by De Nederlandsche Bank (DNB) under Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions (EMD2). It is a national licence: it does not give a passport to other EU/EEA states. Ownership changes need the regulator's approval before completion.
At a glance
| Official name | Exempt electronic money institution registration (Vrijstelling elektronischgeldinstelling)1 |
|---|---|
| Issued by | De Nederlandsche Bank |
| Jurisdiction | Netherlands |
| Licence family | Electronic money institution (EMI) |
| Legal basis | Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions (EMD2)2 |
| Passporting | Domestic only |
What it lets you do
- Issuing electronic money
- Execution of payment transactions
- Money remittance
- Issuing payment instruments and acquiring payment transactions
- Payment initiation services
- Account information services
- Issuing electronic money. Issuing monetary value stored electronically against funds received, redeemable at par and accepted by third parties as payment.
- Execution of payment transactions. Executing direct debits, card payments and credit transfers, including standing orders, from a payment account.
- Money remittance. Receiving funds from a payer solely to transfer them to a payee or another provider, without opening payment accounts.
- Issuing payment instruments and acquiring payment transactions. Issuing cards or other payment instruments to payers, and acquiring card and other payment transactions for merchants.
- Payment initiation services. Initiating a payment order at the user's request from an account held with another provider, as in open banking.
- Account information services. Providing consolidated online information on one or more payment accounts the user holds with other providers.
Where it is valid
Buying a company that already holds it
Prior approval required. Under Section 3:95 Wft and MiCA Articles 41 and 83, acquiring, increasing, or disposing of a qualifying holding (direct or indirect holding of 10% or more of voting rights or shares, or exercising significant influence) in a payment institution, EMI, or ART issuer requires a prior Declaration of No-Objection (DNO / VVGB) from DNB (the ECB assesses banks). Threshold bandwidth upper limits are set at 20%, 30/33%, 50%, or 100%. The statutory decision period is 60 working days from receipt of a complete application, extendable once by up to 30 working days for RFIs, governed by lex silencio positivo.3
Laws behind it
Sources
- dnb.nl: exemption from the authorisation requirement · retrieved 2026-09-24
- eur-lex.europa.eu: HTML (32009L0110) · retrieved 2026-09-24
- dnb.nl: dno application time frame · retrieved 2026-09-24
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