🇳🇱 Netherlands vs 🇬🇧 United Kingdom: e-money licensing compared
Choosing between Netherlands and United Kingdom for a e-money licence starts with who you will answer to: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) on one side, Financial Conduct Authority (FCA). on the other, via the Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence and the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. respectively. The two regimes differ on 7 of 10 tracked decision dimensions, including local substance and application cost. Every figure behind the comparison carries a last-verified date and a primary source.
Netherlands: verified 2026-07-03 · United Kingdom: verified 2026-07-03
| Dimension |
🇳🇱 Netherlands
partly open
Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
|
|---|---|---|
| Licence type | Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) | Financial Conduct Authority (FCA). |
| Capital requirement | Netherlands capital requirement is locked. Unlock with the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Netherlands local substance is locked. Unlock with the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Netherlands application cost is locked. Unlock with the £349 pass. | FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional. |
| Ongoing cost | Netherlands ongoing cost is locked. Unlock with the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Netherlands passporting is locked. Unlock with the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Netherlands emis authorised is locked. Unlock with the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Netherlands key restrictions is locked. Unlock with the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Netherlands safeguarding is locked. Unlock with the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| Recent changes | EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months). | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. |
| Difficulty rating | Netherlands difficulty rating is locked. Unlock with the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
The two regimes differ on 7 of 10 tracked decision dimensions, including local substance and application cost. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇳🇱 Netherlands (verified 2026-07-02): EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months).
🇬🇧 United Kingdom (verified 2026-07-03): FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.
Quick answers
Who regulates e-money licensing in Netherlands and United Kingdom?
Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor). United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Netherlands compared with United Kingdom?
In Netherlands the authorisation route is Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence; in United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Netherlands vs United Kingdom comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/netherlands-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.