When you need it
The licence triggers when you execute payments as a service: holding merchant funds in the flow, running payouts to third parties, initiating transfers, aggregating account data. Pure software vendors whose customers’ money never touches them stay outside — the boundary analysis is the first session, and often reshapes the product flow itself.
The file the supervisor expects
A programme of operations per payment service; governance with fit-and-proper day-to-day management in the Netherlands; initial capital per service class; safeguarding — client funds separated on dedicated accounts or secured, designed with the banking partner before filing; outsourcing, IT-risk and incident frameworks; and anti-money-laundering machinery sized to the model. Complete files move in months; gaps add quarters.
The build-up path
Many platforms launch as agent of a licensed institution — live in weeks under someone else’s ticket — and graduate to the own licence when margin and control justify it. The entity chart stays standard either way: licence BV, holding above, the substance file doing double duty: the wider map, the skeleton and the standard.