Outdated browser

You are using an outdated browser. DNB.nl works best with:

Consultation good practices sub-merchants

Supervision consultation

De Nederlandsche Bank N.V. (DNB) has prepared this good practices document to provide payment institutions and electronic money institutions (hereafter: PIs and EMIs or institutions) with guidance on how to manage risks related to the provision of services (directly or indirectly) to sub-merchants. This good practices document contains guidance on the SIRA as well as policy and procedures regarding customer due diligence and transaction monitoring in relation to sub-merchants.

Published: 12 December 2023

Supervision consultation closed

This Supervision consultation is closed. It is no longer possible to respond.

DNB observed that the institutions have been increasingly setting up different constructions with their clients in order to provide services to sub-merchants. Therefore, in 2022, we conducted a thematic examination into selected PIs and EMIs that use different partnership constructions to offer payment services to sub-merchants to gain insight into the integrity risks associated with this practice. In addition, we investigated which control measures the selected institutions had implemented in order to mitigate the associated integrity risks. Risk management always requires customisation. This also applies to the risks associated with sub-merchants. The examples presented in this good practices document will not always be directly applicable to every institution.


You can respond until 25 January 2024. Responses on this consultation can be send to DNB through the e-mail address consultatie@dnb.nl. Please include Consultation good practices sub-merchants in the subject line. If you give us your written consent, we will publish your consultation response including your name and/or function. Without your written consent, we will only publish the content of your reaction and, where applicable, the name of your organisation. Thus without your name and/or function. You can revoke your consent at any time by e-mailing consultatie@dnb.nl though it does not alter the legality of the publication of your name and/or function in the period leading up to the moment that the consent has been revoked.

For more information regarding the processing of your personal data by DNB and your rights under the GDPR please view our privacy note.

Adoption and publication of policy statement

After receipt, weighing and processing of the consultation responses DNB will decide on the adoption and publication of the final version of the consulted policy statement. DNB will communicate on the outcomes of this consultation through dnb.nl, including a feedbackstatement in which DNB (on an aggregated level) responds to the consultation responses. DNB will publish the content of the consultation responses on the website of DNB and where applicable including the name of the organisation. In case written consent is given, DNB shall publish the consultation responses including name and/or function.


Good practices sub-merchants

Download Good practices sub-merchants

Discover related articles