The process of applying for a licence as a bank has two phases: the preliminary phase and the formal phase. The statutory consideration period for an application to be authorised as a bank is 26 weeks. The consideration period will start when DNB has received your formal application for a licence.
Before proceeding to a formal application for a licence, we would advise you to use the opportunity to discuss you application informally with us first. During this preliminary phase, we can assess your draft application before you submit your formal application.
Before you submit your formal application, you are welcome to discuss your intended activities and their feasibility with us first. This briefing will be based on a tangible business plan, without a full application being required. We will give you feedback on the content of your business plan and inform you about the application process.
Your business plan should at least address the financial projections for the first three years, the required capital and a summary of the proposed activities. We will assess the business plan against the submitted projections and a series of key questions about the business model and strategy1. Other topics that you may address in your business plan are the proposed governance (management board and supervisory board) and aspects relating to sound and ethical operational management (including compliance, internal audit services, outsourcing and ICT).
You can submit a draft application, which we will assess free of charge. We will then send you a detailed written response on the completeness and quality standard of the submitted documents, and we will inform you about any supplementary information that we would need if you intend to submit a formal application for a licence.
After the informal preliminary phase, you can use the IMAS Portal to submit your formal application. Although the ECB will issue the final decision on your application for a licence, we will first verify whether your institution complies with all statutory requirements. If you are unable to demonstrate that you comply with all requirements, we may reject your application. If your application is incomplete or incorrect, we will give you the opportunity to supplement your application within a set deadline. The ECB may also ask you for information directly.
The application procedure comprises several steps. For example, we may ask you to provide supplementary information and (suspending the deadline for consideration), we may schedule a meeting and we need to assess your institution's policy makers. We have prepared an overview of the steps that you may need to go through.
The time needed to consider your application greatly depends on its quality and completeness, and on the supplementary information that you provide. If this is insufficient, it may take more than 26 weeks before you receive the ECB's decision.
On 24 January 2024, the European Commission published its plans for the revision of the European macroprudential framework for banks. An important theme within this evaluation is the usability of capital buffers during a crisis.
Read more Ministry of Finance and DNB make recommendations for a more consistent use of the Countercyclical Capital Buffer in Europe
Starting January 9, 2025, DNB will request information on potential conflicts of interest through the fit and proper assessments application form.
Read more Fit and Proper Assessments: additional questions on potential conflicts of interest
On 31 May 2023, DNB announced an increase of the countercyclical capital buffer (CCyB) to 2%. Banks with loans outstanding in the Netherlands must comply with this requirement since 31 May 2024. DNB is required to determine the height of the CCyB on a quarterly basis.
Read more DNB maintains Countercyclical Capital Buffer at 2% – December 2024
DNB has reviewed the identification and buffer requirements for systemically important banks and maintains the current requirements.
Read more DNB maintains buffers for systemically important banks
