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Exemption from the authorisation requirement


Any party issuing money on a commercial basis in the Netherlands must either hold the appropriate authorisation issued by DNB or be exempted from such authorisation. "Small" electronic money institutions may apply for exemption. They are allowed to operate in the Netherlands without authorisation after submitting evidence to DNB that confirms that they meet specific conditions and after DNB has entered them in its public register.

Published: 26 June 2017

If you want us to enter your enterprise as an exempted electronic money institution in our public register, please use the notification form. For the time being this can only be sent in written form.

You must first verify whether your enterprise actually qualifies as an electronic money institution, based on Section 1:1 of the Wft. You will find more information on this page: Definition of electronic money institution.

The notification form will ask you to provide legal evidence confirming that your enterprise qualifies as a electronic money institution. We recommend that you consult an expert to support you in the application process, a legal adviser for instance. Practice has shown that applications are often more complete and of a substantially higher quality if the applicant has sought expert advice. This enables us to consider applications more quickly and more thoroughly.

Conditions for exemption

We can only enter your enterprise in the public register as an exempt electronic money institution if you demonstrate that you meet the conditions listed in the Exemption Regulation under the Wft (Vrijstellingsregeling Wft). Exemption is subject to the following conditions.

  • Your enterprise only issues electronic money by means of a payment instrument, or an electronic money account on which at most EUR 150 can be stored at any one time.
  • The total amount of liabilities outstanding in relation to electronic money does not exceed EUR 5,000,000.
  • The individuals determining or co-determining the enterprise's operating policies have no negative antecedents as meant in Section 6(a), (b) and (d) of the Decree on Prudential Rules for Financial Undertakings (Besluit prudentiële regels Wft – Bpr) that relate to money laundering, terrorist financing, offences against property or instances of non-compliance with financial supervision legislation that constitute criminal offences.
  • The enterprise can safeguard the fees it gets in return for providing electronic money, either by using a customer accounts foundation (stichting derdengelden), taking out an insurance policy or obtaining a guarantee from a bank or insurer.
  • Your enterprise does not issue electronic money through agents.


Once you have established that your enterprise meets all the conditions set by the Exemption Regulation under the Wft, you can ask DNB to enter your enterprise in the public register as an exempt electronic money institution. Please complete the notification form, sign it, and enclose all the required documents. Please send the form and enclosures to:

De Nederlandsche Bank NV
Expert Centre on Market Access
Postbus 98
1000 AB Amsterdam

We will then verify whether your enterprise qualifies as an electronic money institution and, if so, whether it meets all the conditions for exemption. If it does, we will enter your organisation in our public register as an exempt electronic money institution and you may start providing services. If your enterprise does not meet all the conditions for exemption, please be aware that you may require authorisation and must take action in good time.

Please note: Registration in our public register as an exempt electronic money institution does not mean that your enterprise becomes subject to our regular supervision. This means that you must always make explicit mention of the fact that your enterprise is not subject to our supervision when referring to your registration on your website, in your correspondence or in any other forms of communication. Not being subject to our supervision does not mean, however, that you have no obligations as an exempt electronic money institution.

Obligations of an exempt electronic money institution

As an exempt electronic money institution, you are obliged to inform us about any change in the enterprise's situation that is relevant to its exemption. Examples include an increase in the geographic scope of its services, e.g. if it starts providing services to parties outside the Netherlands, a change in the managing directors' antecedents, or expected total outstanding liabilities in excess of the EUR 5 million threshold. If your enterprise does not meet (or no longer meets) the conditions for exemption, you will not be able to take recourse to the exemption immediately after this has been established.

We would therefore recommend that you prepare your application for authorisation as an electronic money institution well ahead of time, as you may otherwise run the risk of being in breach of the law as you no longer comply with the conditions for exemption. If this happens, you will have to cease operating as an electronic money institution.

Even if you are in the possession of an exemption as an electronic money institution, you will still be liable to comply with the obligations in terms of market conduct supervised by the Authority for the Financial Markets (AFM). We also want to emphasise that exempt electronic money institutions also falls under the scope of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en het financieren van terrorisme – Wwft). Exempt electronic money institutions are therefore required to notify FIU-Netherlands of any unusual transactions and they must perform customer due diligence reviews.

Concurrence with exemption as a payment service provider

If an electronic money institution also wants to provide payment services that are not inherently related to the issue of electronic money, it must notify DNB of this separately. We will then assess separately whether your enterprise also qualifies for exemption for payment service providers. You can find the requirements for payment service providers on: Authorisation exemption for payment service providers.