Revised explanatory notes for payment and e-money licence applications

De Nederlandsche Bank (DNB) has outlined a clearer, two-phase licensing procedure for payment service providers and electronic money institutions.

The initial Phase 1 focuses on verifying the completeness of the application, ensuring all required documents are submitted.

An incomplete submission at this stage can lead to significant delays or even dismissal, underscoring DNB's strict adherence to procedural requirements.

Only upon successful completion of Phase 1 does the process advance to Phase 2, which involves a substantive assessment of the applicant's organisational setup, business operations, governance, and crucially, measures for safeguarding third-party funds.

DNB explicitly advises applicants to ensure their submission is complete from the outset, as incomplete applications may be dismissed after a single request for missing documents, with applicable fees still being due.

Consulting the revised explanatory notes thoroughly is therefore essential to increase the likelihood of a smooth and successful application process, preventing unnecessary setbacks.

A significant update in the revised notes concerns the safeguarding of third-party funds, which must remain strictly separate from the institution's own assets.

Applicants can choose from three distinct methods: establishing a customer accounts foundation, utilizing a segregated assets account, or securing an insurance policy or guarantee.

DNB highlights a recurring issue in past applications where proof of an opened bank account for methods 1 or 2 was frequently missing.

This omission often resulted in substantial delays or outright dismissal due to incompleteness.

To address this, the revised notes now explicitly require either proof of an opened bank account or a bank-signed commitment letter confirming account opening and blocking until the licence is granted.

This ensures robust protection for payment service users' and electronic money users' funds.