When you need it
The licence applies when you provide payment services. This is the case if you hold client funds at any point, make payouts to third parties, start transfers or collect account data for others. Software vendors fall outside this rule if their customers’ money always stays out of their hands. The first step is often to find out exactly where the boundary is. The answer can change how you build the product.
The file the supervisor expects
A programme of operations for each payment service. Governance with suitable and reliable day-to-day management in the Netherlands. Initial capital for the service class. Safeguarding: client funds are separated in dedicated accounts, or otherwise protected, set up with the banking partner before you apply. Rules for outsourcing, IT risk and incidents. Anti-money-laundering checks sized to the business model. A complete file can take months to process. A file with gaps can take much longer.
Starting as an agent
Many platforms start as an agent of a licensed institution. They can then go live within weeks under someone else’s licence. They apply for their own licence later, when they want more margin and control. The company structure is the same in both cases: a licence BV with a holding company above it, and one substance file for both. See the overview of fintech licences, the startup holding structure and the substance standard.