De Nederlandsche Bank (DNB) assesses incumbent and prospective policymakers, such as management and supervisory board members, for fitness to fulfil their duties and whether their propriety is beyond doubt. In conducting our assessments, we also take any antecedents into account.Read more
How to apply successfully
All electronic money institutions applying for authorisation will want the procedure to progress as quickly as possible and will want to be issued authorisation. We will do everything in our power to ensure a smooth and straightforward consideration process.
You can make the difference
You can also speed up the process yourself. We have looked at successful past applications to identify success factors. Obviously, complete and correct applications will be more successful.
These are the success factors for a smooth application for authorization:
- Thorough preparation
It helps if you are aware of the different aspects involved in making an application, and why and how we assess its components. We have put 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 item what we expect from you
- List of activities requiring authorisation, against which you can check whether your enterprise actually needs authorisation, for instance 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 additional information. This will take time, and the consideration period will not start. So be sure to submit a complete application. You will find more detailed instructions in the application form and the notes to the form.
- Quality of your application
If you thoroughly substantiate your application, demonstrating for each aspect how you satisfy the authorisation requirements, we will be able to assess all aspects of your application swiftly. High-quality information provides strong "evidence" in support of your application and enables us to complete the procedure more quickly.
- Consult a legal expert
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 auditor who specialises in the Dutch Financial Supervision Act. We can assess a complete and well-substantiated application more quickly and more thoroughly.
We often see the same points being overlooked in applications for authorisation. Before submitting your application, be sure to go through the following checklist.
- Does your enterprise 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 auditor issued an unqualified opinion on your financial statements?
- Does the enterprise have a footprint in the Netherlands?
- Are there any integrity issues or antecedents involving proposed policymakers or co-policymakers that we have to know about? Applicants sometimes propose to appoint directors on whom we, or another supervisory authority, previously issued a negative decision or who have come under criminal investigation. Be sure to check these issues before submitting your application.
Applying for authorisation
- Electronic money institutions