Access to SFD systems (including TARGET Services)

What does this mean for you? 

As an NB-PSP seeking access to an SFD system, you must demonstrate that you comply with the requirements set out in Article 35a(1) of PSD2. These requirements are intended to safeguard the stability and integrity of the payment system. In short, Article 35a of PSD2 provides that NB-PSPs requesting participation in an SFD system must have: 

1. a description of the measures taken to safeguard users’ funds; 
2. a description of the governance arrangements and internal control mechanisms for the payment services or electronic money services they intend to provide; 
   • Where relevant, the connection to the selected SFD system and the impact thereof on business operations must be taken into account. In case (process) steps and/or decision‑making related to access to the SFD system are (partly) outsourced to, for example, sister and/or parent entities, this must be explained; 
3. a revised winding-up plan (recovery and exit plan) in the event of insolvency. 

When connecting to an SFD system, NB-PSPs are expected to supplement their winding-up plan with an explanation of the recovery, resolution and exit measures that specifically relate to the relevant system access and the impact of such access on the business operations. 

If DNB is your home supervisor, you must notify DNB of your compliance with the above requirements (as also laid down in article 26bb of the Decree on Prudential Rules under the Financial Supervision Act). For this purpose, DNB expects you to address the following information in your notification as well: 

A description of the expected impact on the organisation as a result of connecting to an SFD system, including the impact of complying with applicable PSD2 requirements for the purpose of the SFD system connection. This should also specify which “gaps” compared to the situation prior to the SFD system connection have been identified and how these gaps will be addressed. 

A statement signed by the management board of the NB-PSP confirming that it complies with the requirements of Article 35a PSD2. 

How does the process work? 

Step 1 – Application to the system operator 

• You submit your formal application for participation to: 
  • the central bank (in the case of TARGET Services), or  
  • the operator of the relevant SFD system. 

Step 2 – Submission of information to DNB or the home supervisor 

• After submission of your application, the operator of the SFD system will submit a request to DNB for the assessment of compliance with Article 35a PSD2 by the NB-PSP. The NB-PSP must notify DNB accordingly, after the system operator confirms the application and has notified DNB about this application, where required information is sent to DNB. You can use the attached Excel form below to submit this information, which is to be sent via email to infobetaalinstelling@dnb.nl, with the following subject:  

  “[Name NB-PSP] access to payment system [name system] – documentation art. 35a PSD2”.

• Should DNB require additional information, the supervisor may contact you directly. Please share the name of the contact person and the relevant email address in your correspondence on the requested information. 

Step 3 – Decision-making 

After reviewing the compliance with Article 35a PSD2 by the NB-PSP, it is for the relevant system operator to decide on participation in the SFD payment system. The notification of DNB as home supervisor is but one requirement in the approval process in the case of application for access to TARGET Services. You can find out more about this process here, in the case of applications with DNB as the operator of TARGET NL. 

After admission 

After obtaining access to an SFD system, DNB expects you to:  

• promptly notify any changes relating to your PSD2 compliance that are relevant for your SFD system access;  
• to submit an annual statement on your compliance with Article 35a PSD2;  
• and to inform DNB as soon as possible of any material events affecting your participation in an SFD system.