Published: 17 March 2022
A payment service provider applying for authorisation will want to receive it as quickly as possible. We will do everything we can to make sure that the consideration process is smooth and swift.
Making a difference
You can also speed up the process yourself. Below, we list how you can do so. We have looked at successful applications in the past to identify success factors. Obviously, completed and high-quality applications will be more successful.
The success factors for a smooth application for authorisation:
Be sure to understand the various aspects involved in an application, and why and how we assess its components. We have placed the following background information on our Open Book on Supervision website:
- The relevant sections of the law , so that you know the statutory provisions that apply
- Notes to the authorisation application form , listing for each subject what we expect from you
- List of payment services requiring authorisation, against which you can check whether your enterprise actually needs authorisation, preferably with the help of a legal expert
- Fully completed application
This may sound like stating the obvious, but if your application is incomplete, we cannot start considering it and will ask you to provide more information. This will take time, and our consideration period will not commence. So be sure to submit a complete application. More detailed instructions are provided in the application form and the notes.
If you thoroughly substantiate your application, demonstrating for each aspect how you satisfy the requirements, we will be able to assess those aspects swiftly. High-quality information provides strong "evidence" in support of your application and enables us to go through the process more quickly.
Consult a legal adviser
Practice has shown that applications are often more complete and of a substantially higher quality if the applicant has sought advice, for example from a legal expert or an advisor who specialises in the Dutch Financial Supervision Act (Wet op het financieel toezicht – Wft). We can assess a complete and well-founded application more quickly and more thoroughly.
We often note the same oversights. Before submitting your application, be sure to go through the following checklist.
The following points are often overlooked in applications for a licence, so we would advise you to check these before submitting your application:
- Your company must be able to operate on a sufficiently independent basis from group entities. Your governance structure must have adequate safeguards in place to ensure this (e.g. having a Supervisory Board). For more information, see the explanatory notes to the application form.
- Does your institution have sufficient capital at its disposal (own funds and solvency)?
- Is segregation of assets guaranteed? (safeguarding of funds)?
- Are financial statements available that we can verify?
- Has an independent auditor issued an unqualified opinion on your financial statements?
- Does your institution have a footprint in the Netherlands?
- Are there any integrity issues or professional history antecedents involving proposed policymakers or co-policymakers that we need to know about? Applicants sometimes propose appointing a board member on whom we, or another supervisory authority, previously issued a negative decision or who is subject to criminal investigation. Be sure to check these points before submitting your application.
Shareholders may be required to hold a declaration of no-objection (DNO), so ensure they have applied for it in good time. A DNO requires applicants to submit a substantial number of documents, so it may take some time to complete the application. We therefore advise you to start the process as early as possible, as we cannot issue a license without the required DNOs having been issued. Please also refer to ‘DNO for shareholdings (Section 3:95 of the Wft)’.